Corrective Action Orders

The issuance of a Corrective Action Order (CAO) can have significant and ongoing consequences for a pipeline operator.  A powerful enforcement tool typically associated with the shutdown of a pipeline facility, a CAO often means numerous compliance obligations and significant disruption of normal operations, not to mention the stigma accompanying a CAO’s pre-requisite finding that continued operation of a pipeline facility would be “hazardous to life, property, or the environment.”  49 U.S.C. 60112(a)(1).
Continue Reading Corrective Action Orders: Targeted Use, Expansive Requirements