In response to NTSB Recommendations and the 2012 amendments to the Pipeline Safety Act, PHMSA has issued guidance to operators to ensure that the MAOP and MOP of all liquid and gas pipeline segments are supported by records that are “traceable, verifiable and complete.” This Advisory marks the first time that PHMSA has issued guidance with regard to the meaning of this standard that originated with the NTSB and was restated in a PHMSA Advisory issued in January 2011. Unfortunately, it is still far from clear how an operator must comply with the standard. While acknowledging that “other types of records may be acceptable and that certain state programs may have additional requirements,” PHMSA provides limited additional guidance with regard to the meaning of the terms “traceable,” “verifiable” and “complete.” Beginning in 2013, as directed by the 2012 amendments to the Pipeline Safety Act, PHMSA will require gas operators to submit data regarding pipeline mileage with and without verifiable records in their annual reports. This information will then be used by the Agency to develop additional guidance and/or rulemakings with regard to: (1) how operators will be required to bring their gas and liquid pipelines without verifiable records into compliance for the entire mileage of the pipeline; (2) how operators will be required to reestablish MAOP; and (3) whether to eliminate the grandfather clause under 192.619. Click here for the Notice to be published in the May 7, 2012 FR.