And how it will affect your Inspection and Maintenance plan



On December 27, 2020, President Trump signed the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act into law. Generally, per the PIPES Act mandates, PHSMA or other federal agencies must act before operators are expected to take action—with one exception. One mandate, found in Section 115 (Inspection and Maintenance Plans), requires action by all pipeline operators without any PHMSA rulemaking.

The current rule is that pipeline operators “shall carry out a current written plan (including any changes) for inspection of maintenance of each facility used in the transportation and owned or operated by the person.”

Congress mandates the below as criteria when PHMSA determines the adequacy of the written plan:

  • relevant available pipeline safety information;
  • the appropriateness of the plan for the particular kind of pipeline transportation or facility;
  • the reasonableness of the plan; and
  • the extent to which the plan will contribute to public safety and the protection of the environment.

So, what is changing? The PIPES Act updates Section 60108 with these changes to (D) and adds (E):

  • the extent to which the plan will contribute to –
    • (i) public safety
    • (ii) eliminating hazardous leaks and minimizing releases of natural gas from pipeline facilities; and
    • (iii) the protection of the environment; and
  • the extent to which the plan addresses the replacement or remediation of pipelines that are known to leak based on the material (including cast iron, unprotected steel, wrought iron, and historic plastics with known issues), design, or past operating and maintenance history of the pipeline.

Operators have until December 26, 2021, to update their plans accordingly. PHMSA or state regulators must evaluate each operator’s plan to determine compliance with the new rule by December 27, 2022.

If you need assistance with your O&M or OQ plan, our consultants are standing by to assist you! Call ITS at 800.333.1566, email, or visit our Consulting page to learn more about all the ways in which our team of subject matter experts can help!