Examples of
Federal requirements for manuals and procedures
Why are manuals important for pipeline operators?
The answer is simple. Easy to use, comprehensive manuals are essential for safe and efficient operations and for compliance with federal and state law. They must include content that allows for safe and compliant operations, but equally as important, they must be kept current and accessible by personnel both in the office and in the field at any time.
But implementing this simple answer can be complex. The regulations outlining the requirements for manuals can be confusing, but non-compliance constitutes a violation that can result in an enforcement action. So how can an operator ensure that their manuals are both complete and compliant? And how can an operator ensure access to that information so that personnel can perform tasks in a safe and compliant way?
Here are answers to some frequently-asked questions.
What are the requirements for manuals?
How often are operators cited for violations related to their manuals?
What might be considered a violation of requirements?
How can ViaData help me create manuals with compliant content?
What are the requirements for manuals?
Requirements for written procedures are included throughout the federal pipeline safety regulations in 49 CFR Part 192 - Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards, Part 193 - Liquefied Natural Gas Facilities: Federal Safety Standards and Part 195 - Transportation of Hazardous Liquids by Pipeline.
PHMSA provided the following explanation in its major rulemaking for §192.605 and §195.402 Procedural manual for operations, maintenance, and emergencies:
Gas pipeline operators must maintain O&M procedures on specific topics. The regulation provides a list of required items that must be included, but operators can determine how best to do so for their particular system, so long as it provides for safe maintenance and operations.
Written procedures on those specific topics are essential to safe operation and maintenance of a pipeline. When used properly by trained personnel, the specific procedures should have a positive effect on pipeline safety.
The procedures should be clear, straightforward and applicable to the company's system. Procedures of a general nature provide little guidance when needed.
The manual should be prepared prior to commencing initial operation of a pipeline. Under normal circumstances, long lead times are required for a company to obtain regulatory approval to construct and commence operating a pipeline. This should allow operators sufficient time to prepare the required documents in anticipation of pipeline startup. The operation of a pipeline without O&M procedures would be unsafe, both for those operating the pipeline and for the public.
Operators are expected to maintain a complete set of the volumes of the comprehensive reference manual at one location. Copies of parts of the manual, containing the information pertinent to particular functions or facilities in a system, must also be kept wherever needed for field operations.
Examples of
Federal requirements for manuals and procedures
These requirements are subject to enforcement at both the state and federal levels.
During routine inspections or audits, or after an incident, PHMSA or state regulators will review an operator's written procedures. An operator can be cited for a lack of, or inadequate, procedures. Some enforcements result in substantial civil penalties.
Administrative enforcement procedures and other regulations governing the federal enforcement program are described in 49 CFR 190 Subpart B - Enforcement.
How often are operators cited for violations related to their manuals?
As an example, we can look at some recent PHMSA enforcement statistics* for 49 CFR §§192.605 and 195.402 Procedural manual for operations, maintenance, and emergencies:
| Code section | Enforcement cases 2008-present | |||||
| Eastern | Southern | Central | Southwest | Western | Total | |
| §192.605 | 90 | 37 | 21 | 54 | 120 | 268 |
| §195.402 | 82 | 26 | 59 | 106 | 79 | 273 |
Note that these totals represent only those cases that explicitly cite these regulations. Additional cases that address inadequate procedures may only cite the regulation outlining requirements for a specific task. These are totals from federal enforcements only and do not include enforcements at the state level. Thus these totals are a minimal indicator of the number of cases where written procedures were cited as the basis for a violation.
What might be considered a violation of requirements?
Some general examples of a probable violation or inadequate procedures in an O&M manual (per PHMSA enforcement guidance) include:
Inspectors can be general or quite specific in their determinations of violations.
Examples of
violations from specific cases
Cases where
civil penalties were assessed
How can ViaData help me create manuals with compliant content?
We can create the manuals you need, either from scratch, or by reviewing / restructuring your existing manuals to ensure compliance.
ViaData monitors federal rulemaking activities, and PHMSA's published operator guidance, Advisory Bulletins and enforcement actions for inclusion in our product WinDOT, the Pipeline Safety Encyclopedia. Thus, we are fully aware of federal requirements and we understand how they are enforced. We also maintain a set of pipeline safety regulations for all 50 states as part of WinDOT, so we keep abreast of changes at the state level, as well.
To give context to your company procedures, we include links to pertinent federal and state regulations within all our manuals, and we present state-specific requirements in an easy-to-recognize format.
Our manuals also act as an audit tool for tracking changes and demonstrating compliance with periodic review requirements.
How can ViaData help me ensure that my staff has access to manuals so they can comply with procedures when performing tasks?
A key factor to staying in compliance is the ability of your staff to reference the procedures they need to follow. The usefulness of even the best content is compromised if access to it is difficult or impossible.
We make it easy for all personnel to access your manuals and quickly find the procedures they need by providing secure, fully searchable online access via computer, tablet or phone. Making this your primary distribution strategy ensures anytime-anywhere access to up-to-date content. As a backup, we can also provide manuals in a format suitable for local installation or for printing.