Citing concerns that intrastate and small gas transmission pipeline operators may not be accurately identifying high consequence areas (HCAs) as part of their integrity management programs (IMP), PHMSA issued yet another advisory to the industry on December 12, 2016. In its seventh advisory issued this year, PHMSA explains the need for further guidance on the methodology based on recent inspections as well as a Safety Recommendation issued by the National Transportation Safety Board (NTSB) in 2015 (NTSB Recommendation P-15-06, issued in conjunction with the Board’s Safety Study of implementation of gas transmission integrity management rules).
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Advisory
The Legal Effect of Advisories and Guidance
By Hunton Andrews Kurth LLP on
Posted in Practice Pointers
Over the past several years PHMSA has issued numerous Advisories and Guidance notices. In fact, the Agency has issued nine times more informal guidance documents than formal rulemakings on pipeline safety issues since January 2012.
Continue Reading The Legal Effect of Advisories and Guidance