Can risk ranking be done by piggable sections, since that is the way my assessments will be conducted?
The rule requires that an operator must use risk assessment to prioritize covered segments for baseline assessments and reassessments (192.917(c)). OPS expects to see a ranking by covered segment. Operators will need to manage their assessments, and some aggregate indication of risk, by piggable section, could be useful in that regard. Such aggregation can mask important information, however. For example, a number of low-risk covered segments in a piggable section could result in that section being determined to be of moderate risk even though it contains the highest risk covered segment in an operator’s program. Operators need to know the relative risk of individual covered segments so that they can appropriately plan their assessment activities.
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