Five Principles for Maintaining Accurate and Complete Integrity Records

Have you been maintaining accurate and complete integrity records? If PHMSA notified your company of a pending audit for integrity records, would you be filled with confidence or anxiety? How did your company’s last audit go? Do your records tell the story for each feature from tool-out date through inspection and repair?

If reflection on past audits causes a twinge of concern, perhaps there were features that were inspected, but lacked adequate documentation. Or maybe you missed an inspection deadline altogether, due to a communication error.

Whether your program is well established and firing on all cylinders, or if it’s still in need of development, there is always room to learn to learn from the experience of others.

For more than 15 years, HT Engineering has assisted clients with their Integrity Programs. Along the way, we have seen common issues that operators are battling, and have developed some principles that can help your program grow to its full potential and increase your confidence when the next audit comes along.

Why Audits?

The Pipeline and Hazardous Materials Safety Administration (PHMSA) and pipeline operators share an interest ensuring pipelines remain safe. This means taking measures to “keep it in the pipe,” preventing the release of product that could cause damage to property, pollution of the environment, and/or threats to public safety and security. To mitigate these threats, PHMSA requires that pipeline operators conduct integrity assessments of their lines on a recurring basis.

One integrity assessment method is in-line inspection, which uses smart pigs to detect pipe defects that may be a threat to the integrity of the pipeline. These features are then prioritized into buckets based on criteria including severity, the co-incidence of multiple types of features, the pipeline’s proximity to highly populated areas or areas where people congregate, as well as environmentally sensitive areas.

This prioritization uses established protocols for determining how quickly an operator must excavate and inspect, and possibly repair after verification of features.

During an audit, PHMSA is looking for two basic things:

1. Does the operator have a program in place that complies with PHMSA requirements to ensure safe operation of the pipeline?
2. Is the operator following that program?

Accordingly, an operator’s Integrity Program should ensure that:

1. The program addresses PHMSA requirements with appropriate policies and procedures
2. Activities in the engineering office and in the field are documented in a way that clearly shows compliance with PHMSA and company requirements.

If a company can quickly and successfully demonstrate the above, it builds PHMSA’s confidence in the competence and motivations of an operator. If an audit results in “findings” (gaps in the process or documentation), it can result in warnings or a notice of violation. This can carry financial or, in extreme cases, criminal penalties for the organization and/or its employees.

A history of findings casts a shadow over future audits and ensures PHMSA will be looking very closely for both repeat and new gaps in the process and/or documentation at future audits.

Image provided by Bryan Mulcahy of Integrated Inspection.

Threats to Maintaining Accurate and Complete Integrity Records

In HT Engineering’s history of supporting pipeline operators, we have seen several common threats that can negatively impact documentation and compliance with PHMSA requirements.

1. Field employees typically like to do work… not paperwork. Sometimes field folks don’t see the value of documentation. They are certainly motivated to do quality work and ensure the product stays in the pipeline, but may not see the purpose of writing down something they know was done right.
2. Quality Control of documentation is not prioritized. Quality control may be lacking for several reasons. If an operator has a veteran workforce, they may simply trust their personnel to do their job well. The need to double check the field employees’ work may not seem necessary. There’s also a lot going on and people are busy. If documentation issues haven’t been a problem before, it’s tempting to focus time and energy on other tasks and skip the quality check.
3. Records may be stored in a manner that makes future reference difficult. The records may have been completed in the field, but if you can’t locate them during an audit, it’s as if they don’t exist. People naturally have different inclinations when it comes to documentation. Some people naturally file paperwork in an organized manner. Others may have a years’ worth of documentation piled in a box in the back corner of the office, or on the floorboards of their truck.Even if you do have all the paper records organized in one location, inspections have been done remotely during COVID and this is likely to continue to some degree. The ability to access record systems electronically from a remote location is a must these days.
4. Field and office personnel may have different skill sets when it comes to information technology. Technology can be a wonderful thing! Still, its effectiveness is limited by individual experience and comfort levels on various platforms. A knowledge or experience gap between office and field personnel regarding technology can result in incomplete or even lost records.
5. Inconsistent naming conventions can make it difficult to tie field activity back to the official records in the Engineering Office. In the past, our engineers would get calls from the field and spend the first five minutes of the conversation trying to align on what feature they were talking about. If your field team refers to a dig as “the First Street dig” and your engineering office calls it “Line 7 ODO1657.47,” there is bound to be confusion in the records.
6. Communication lapses leading to missed deadlines. It is not uncommon for features to change buckets due to updated information from tool vendors or subsequent tool runs. If the engineering office simply hands the initial repair plan over to the field team and isn’t involved again until the set of digs is “done,” you could be asking for trouble. Without someone shepherding a repair plan, adjusting priority throughout the duration of process and communicating with the field, it’s easy to miss a deadline which can lead to a notice of violation and fines.

Image provided by Bryan Mulcahy of Integrated Inspection.

Principles for Maintaining Accurate and Complete Integrity Records

Culture is KING!

How you frame the requirements for documentation to field personnel will make a big difference. Typically, field personnel are not required to sit through PHMSA audits, so it’s important to help them understand how their documentation helps or hinders others. If you are fortunate, they might naturally see documentation as something that’s important even without the explanation, but more often they might see it as “Big Brother” watching over them, looking for mistakes.

Several years ago, we started emphasizing documentation as a story telling tool. We tell field level inspectors that three to five years after they finish their work, someone who wasn’t there will have to walk the auditors from start to finish through the story of each specific location. And again, you need to realize that for PHMSA auditors if it isn’t on paper, it didn’t happen… even if your employees know they did a good job.

Over several years, we’ve seen an attitude shift from the field, and although they still may not enjoy documentation, they can now see the role it plays in helping others tell their story later.

A Digs Coordinator is a must

Typically, integrity digs involve a lot of moving parts that require different departments to work closely together.

The Land Group (ROW) has to confirm easements and possibly obtain local permits. Environmental may need to get permits for work in wetlands or other sensitive features. Contractors may require heavy haul permits for equipment in addition to making their one-call notices. Engineering may need specific feedback at particular locations in order to refine their data models.

And that’s for “typical digs.” Features in particularly difficult locations often involve more stakeholders that need to be managed. While each group knows how to do their part, it’s critical for there to be someone managing the process, directing the communications, stewarding location prioritization, and clearly communicating to the team, .

If Environmental and ROW work through their responsibilities without coordinating communication, you can easily end up with sites that are clear from ROW, but not Environmental and vise versa. This leaves a crew ready to mobilize with no where to go, getting paid down time while waiting for permits. Even worse, you could accidentally dig a site before it’s been cleared because one group gives their “all clear” notice, but no one double checked if that was the last step required.

Quality Control (QC) is key to having a clear story to tell later

For quality control to be successful, we have discovered the following important principles:

• QC personnel must be tied in with both the field and engineering (and/or regulatory) office to act as a liaison and communicator between the two groups regarding documentation needs, procedures and compliance.
• The QC process must be supported by management and encouraged in the field.
• Use QC personnel not just to check for errors but as trainers with field personnel. QC personnel should spend time with the field staff, on site, working through documentation together. The QC person can spot common errors and then train new personnel to avoid the same mishaps.
• QC personnel must be familiar with the fieldwork to understand what information the field staff could potentially miss or misinterpret.

Choose a documentation and record-keeping work flow and technology that is appropriate for your company

Having the latest and greatest database or data collection technology does not necessarily mean you have great records.

If your company has a large IT support staff, then going fully electronic or Cloud based may be your best option. But if you have limited IT support, then going fully automated may be more than you can keep up with, resulting in lost or misplaced records. In such a case, paper records, converted to PDFs, may be your best choice.

Putting a system in place and having everyone know how to navigate the system successfully, are two very different things. No matter which system you chose, clearly define the expectations at each step for how data gets from the field to the records office and spend the time necessary to ensure your personnel can meet the expectations. It will take time, and you will have to make some adjustments as you listen to feedback from those involved, but it’s time well spent.

Develop a program “desk procedure” document as a reference for current and future Integrity Personnel

Consistency assists in obtaining complete records and is often a key indicator of accuracy. Each repair plan should be handled with the same rules and documentation from start to finish.

As auditors look through records, they should find similar format and level of detail for every line segment, location, and feature. As we have developed the Integrity Program for one of our clients, we found it helpful to align and document consistent processes for the following:

• Feature and dig site naming conventions
• Desk top site reviews: Who to include and what topics to cover
• What documents are needed from each site, as well as document naming conventions
• What documents should be included in the repair plan reconciliation process
• Workflow for submitting, performing QC, and storing records for integrity digs
• Where and how records are stored (both physically and electronically)

Benefits of a Great Integrity Records Program

A solid Integrity Records Program can:

• Help keep the product in the pipeline by ensuring that all required inspections and repairs are completed in a timely manner
• Turn external audits into an opportunity to celebrate team success rather than stress about potential program gaps
• Allow employees to stay focused on current work rather than spend countless hours fixing gaps in past work

The Benefits of Outside Help

An Engineering firm specializing in Integrity work can help you:

• Audit your current records and process
• Advise on records and process improvements based on industry experience
• Train QC and/or field personnel on documentation procedures
• Support or manage company stewardship of required inspections and repairs
• Participate in and support the pipeline operator in the audit process

Contact us today to learn more about how we can help you.