There is great emphasis today that records for establishing MOP and MAOP are traceable, verifiable and complete. In Advisory Bulletin (ADB-2012-06) PHMSA defined these terms as follows:
Traceable records are those which can be clearly linked to original information about a pipeline segment or facility. Traceable records might include pipe mill records, purchase requisition, or as-built documentation indicating minimum pipe yield strength, seam type, wall thickness and diameter. Careful attention should be given to records transcribed from original documents as they may contain errors. Information from a transcribed document, in many cases, should be verified with complementary or supporting documents.
Verifiable records are those in which information is confirmed by other complementary, but separate, documentation. Verifiable records might include contract specifications for a pressure test of a line segment complemented by pressure charts or field logs. Another example might include a purchase order to a pipe mill with pipe specifications verified by a metallurgical test of a coupon pulled from the same pipe segment. In general, the only acceptable use of an affidavit would be as a complementary document, prepared and signed at the time of the test or inspection by an individual who would have reason to be familiar with the test or inspection.
Complete records are those in which the record is finalized as evidenced by a signature, date or other appropriate marking. For example, a complete pressure testing record should identify a specific segment of pipe, who conducted the test, the duration of the test, the test medium, temperatures, accurate pressure readings, and elevation information as applicable. An incomplete record might reflect that the pressure test was initiated, failed and restarted without conclusive indication of a successful test. A record that cannot be specifically linked to an individual pipe segment is not a complete record for that segment. Incomplete or partial records are not an adequate basis for establishing MAOP or MOP. If records are unknown or unknowable, a more conservative approach is indicated.
Over the years questions have arisen regarding the format of the records and are copies, computer files, or other means acceptable.
The following interpretation, while written in 1997 as computers were beginning be used for record keeping in place of paper, still gives guidance on whether a copy of a record is acceptable, as long as it meets the criteria above. And the 1992 interpretation sets the initial stage for this later document.
Interpretation 195.404 6
May 29, 1997
U.S. Department of Transportation
Research and Special Programs Administration
Office of Pipeline Safety
2320 LaBranch, Suite 2116
Houston, Texas 77004
Phone: (713) 718-3746
Fax: (713) 718-3724
Mr. Bryan Chenault, President
Chenault Aviation Services
Beaumont, Texas 77706
Dear Mr. Chenault:
Thank you for your undated letter requesting an opinion of the regulations regarding record keeping and completing a particular RSPA form. These questions had been previously discussed with a member of our staff on April 22, 1997. The first question has to do with § 195.404(c)(3) record keeping requirements of aerial inspections of pipeline rights-of-ways while the second concerns itself with the data required to complete form RSPA F7100.2, Incident Report – Gas Transmission and Gathering Systems.
Firstly, there has been some confusion regarding the record keeping requirements of §195.404(c)(3). The confusion may come from the incorrect interpretation of sentences written in the attached OPS letter dated April 6, 1992. In part, these sentences stated “Also, original hard-copy (paper) records need not be retained after their conversion to magnetic media. However, like the original hard copy records . . . ”
The word ‘original’ has been misconstrued to exclude copies. If magnetic media are acceptable so should paper copies and an operator may use faxes, copiers or other types of copy of inspection records to satisfy the record keeping requirements of §195.404(c)(3).
In regards to the second question, there have not been any OPS interpretations regarding the RSPA form. However, as OPS noted in the attached letter, records must contain sufficient information to comply with the requirements of the applicable regulation or form. Moreover, the instructions for completing the form note that sufficient data should be included to assist in locating the incident on a map. They do not prohibit the annotation of additional information to the form. In actual practice, this is being done by operators who occasionally include maps or additional information with the form. On this basis we conclude that the entire form must be completed and could be supplemented, although not required, with a map showing the location of the incident.
We hope this answers your questions. Please let us know if we can be of further assistance in this matter.
James C. Thomas
cc: Regional Directors
Deputy Associate Administrator
Director, Office of Compliance and State Programs
Pipeline Safety (TSI)
Interpretation 195.404 5
April 6, 1992
Mr. W. N. Hall
Associate Petroleum Engineer
Dome Pipeline Corporation
Plaza Center One
P.O. Box 1430
Iowa City, IA 52244-1430
Dear Mr. Hall:
This is in response to your letter of November 7, 1991, concerning the recordkeeping requirements of §195.404(c)(3). The letter asks whether magnetic media (computer hard drive or diskettes ) may be used in place of hard copies to record and maintain the required records.
Section 194.404(c)(3) requires that each operator maintain a record of each inspection and test required by Subpart F. Records must be maintained for at least 2 years or until the next inspection or test is performed, whichever is longer. Section 195.404(c((3) does not prohibit operators from maintaining the required records on magnetic media. Also, original hard-copy (paper) records need not be retained after their conversion to magnetic media. However, like the original hard copy records, magnetic media records must contain sufficient information to comply with the recordkeeping requirements of §195.404(c)(3).
We trust that this adequately responds to your request. We are sorry we were not able to answer your letter sooner. However, please let us know if we can be of further assistance.
Cesar De Leon
Director, Regulatory Programs
Office of Pipeline Safety
Dome Pipeline Corporation
Plaza Centre One
P.O. Box 1430
Iowa City, Iowa 52244-1430
November 7, 1991
Mr. George Tenley
Department of Transportation
400 7th Street SW, Room 8417
Washington, DC 20590
RE: INTERPRETATION OF SS 195.404 Maps and Records
Dear Mr. Tenley:
We have a question relative to the record keeping requirements of 195.404(c)(3) in that currently we are using hard copies to document the inspections and tests required by subpart 195.404, but would like to convert to recording and maintaining these records of magnetic media (computer hard drive or diskettes).
This proposal would permit the elimination of all hard copies of records with a corresponding improvement in the management of the records. Hard copies however could be printed on demand at any time. The computer records would contain the date and names of the parties making the inspection or test, and in addition when their immediate supervisor would review the records he would also add his name and the date he reviewed the records.
We believe that this proposal meets the intentions of the Part 195, and would be an acceptable alternate to maintaining hard copies of all the records. A favorable interpretation of 195.404(c)(3) relative to our proposal would permit us to enhance our record keeping based on current technology. Computer records would be backed up to insure that the records could always be produced if the primary disk was either damaged or destroyed.
W. N. Hall
Associated petroleum Engineer
Interpretation 192.603 8
May 9, 1991
Mr. Albert T. Richardson
1010 Milam Street
Houston, TX 77252-2511
(ViaData Note – Ref: 192.1 and 192.603)
Dear Mr. Richardson:
This responds to your letter of February 25, 1991, to William Gute. The letter discusses Tenneco’s use of computers instead of paper to record and store information it must maintain under 49 CFR Parts 191 and 192. You asked us to determine standards that would be acceptable in maintaining this information in computers.
Under Parts 191 and 192, operators may use any recordkeeping procedure that produces authentic records, without the prior approval of this agency. The proposed standards enclosed with your letter, which are aimed at ensuring the authenticity of computerized records, are permissible under Parts 191 and 192.
Although authenticity of records concerns us, for both computer and paper records, we do not believe there is sufficient need to adopt generally applicable standards governing recordkeeping procedures. In the absence of such standards, we ordinarily do not review an operator’s recordkeeping procedures unless the legitimacy of records is in question. Accordingly, we have no comments at this time on the adequacy of your proposed standards.
George W. Tenley, Jr.
Associate Administrator for Pipeline Safety
DPS:11, 10, 20, 2, 1
DPS-11:LMFurrow: lfv: 366-2392:5/9/91
All this and more, including the historical regulations and interpretations in WinDOT, The Pipeline Safety Encyclopedia.