Connecting Regulatory Compliance & PSMS

Thinking Beyond the “Word” Compliance

While API RP 1173 does not specifically address regulatory compliance as an “element” of a safety management system, an effective pipeline safety management system has direct and sustainable impacts on an organizations compliance posture. An effective PSMS does address scenarios where work deviates from established standards, considers unforeseen conditions, and helps reveal regulatory conformance issues through an integrated system of risk identification, operational controls & safeguards, investigation, and corrective actions. This holistic approach ensures that unknowns (e.g., unexpected site conditions during excavation or maintenance) or non-conforming work are treated as opportunities for learning and prevention rather than isolated “one-off” failures of compliance.

Regulatory compliance and pipeline safety management are deeply interconnected and work together to ensure the safe and reliable operation of pipeline systems. They compliment each other by establishing regulatory compliance as the foundation (sets minimum legal requirements for design, construction, operation, and maintenance of pipelines) and pipeline safety management systems (API RP 1173) as the vehicle that ensures conformance with these requirements and beyond. Compliance is a natural outcome of addressing elements of API RP 1173.

Description of Event:

During the operation of the Tigercat (street trencher) to remove the paved hard surface for an upcoming main replacement project, a 1" steel gas service was compromised. The service was found embedded at the base of the asphalt. The service was not cut by the teeth of the Tigercat; however, due to its installation in the asphalt, the removal of the top layer led to the steel service being dislodged from the a connection tee at the gas main, resulting in a release of gas.

Key Causal Factors/Root Causes:

Insufficient cover and non-conforming construction practices. Service was installed out of compliance in 1963, not installed to depth and embedded in the blacktop.

Key Corrective Actions:

While the crew was excavating within the rules of State Dig Safe law by removing the top layer with mechanized equipment, a review of the Dig Safe law will be conducted with all regional gas crews re-enforcing “expect the unexpected” with historical installations.

• Highlight that while use of mechanized equipment is allowed in the tolerance zone, it is only allowed to depth of the hard surface. Any depth below the hard surface is a violation of Dig Safe laws and presents unacceptable risk.
• Promote communication about service depths and limited associated information for historical installations surrounding them. We do not always know the standard of work that was done in the past, and it is a leading practice to pothole utilities and verify depths before commencing any excavations.

Key Lessons Learned:

• While Dig Safe Laws were followed correctly in this situation, it is important to review the specifics of the law, and our company policies, so crews have awareness to prevent future incidents.
• Mechanized equipment is permitted in the tolerance zone, but only to the depth of the asphalt/pavement. Do your due diligence to know the depth of hard surface.
• Ensure installation minimum cover requirements are maintained to avoid potential damages and risk to future excavators

NOTE: Regulatory compliance provides the rules; pipeline safety management brings them to life. Together, they provide a “layers of protection” approach to minimize risks to people, property, and the environment while enabling sustainable transportation energy.