How will PHMSA Pipeline Safety ensure consistency in enforcing integrity management requirements?
The integrity management rule contains a number of management-based and performance-based requirements. Determining enforcement action for these types of requirements is fundamentally different than for prescriptive requirements. Enforcement decisions in this area require subjective judgments on the part of inspectors and PHMSA Pipeline Safety managers. PHMSA Pipeline Safety recognizes that ensuring consistency in the enforcement process is very important. To address this task, PHMSA Pipeline Safety has undertaken steps to improve the fairness and consistency in its enforcement process. For example, integrity management inspections are conducted using written protocols that help guide inspectors toward making consistent judgments. PHMSA Pipeline Safety has been conducting reset meetings with inspection teams to review inspection findings and to discuss ranges of appropriate enforcement actions to ensure that appropriate levels of consistency are being achieved. Additionally, PHMSA Pipe
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