Frequently-Asked Question FAQ #160

FAQ-160: Enforceability of beyond-regulation program provisions

Question: Are requirements included in a company's integrity management program that go beyond those in the regulations enforceable by OPS?

Answer: Yes. Section 192.907 requires that "...an operator of a covered pipeline segment must develop and follow a written integrity management program...". Requirements that an operator chooses to incorporate in its program, even though they may go beyond requirements specified in regulations, become a part of the program that the operator must "follow". OPS expects that an operator will implement all activities included in the operator's program. OPS encourages operators to undertake additional activities beyond those required by regulation. However, OPS discourages operators from including those additional activities in their programs if they do not intend to implement those additional activities.

These Frequently Asked Questions (FAQs) are intended to clarify, explain, and promote better understanding of the pipeline integrity management rules. These FAQs are not substantive rules and do not create rights, assign duties, or impose new obligations not outlined in the existing integrity management regulations and standards. Requests for informal interpretations regarding the applicability of one or more of the pipeline integrity management rules to a specific situation may be submitted to PHMSA in accordance with 49 C.F.R. § 190.11.

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