What is PTP, as referred to in the preamble to the proposed rule?
PTP is an acronym for Prevention through People. The actions of people, errors of omission and commission, represent a portion of the risk to pipeline systems. At the same time, positive actions of people (operator personnel, excavators, and others) can help reduce the risk posed by pipelines. Historically, PHMSA has established regulations governing specific aspects of the interactions of people with pipeline systems. These include drug and alcohol requirements, personnel qualification, damage prevention programs, etc. To date, operators have not been required to conduct a holistic evaluation of the potential for the actions of people to affect their pipelines, positively or negatively. Much as the rest of integrity management involves a holistic evaluation to reach beyond the level of safety afforded by specific technical regulations, PTP involves an integrated evaluation of the effects of people to identify actions that will help improve safety from people-related issues more than t
