What is the difference between an acceptable Integrity Management Framework and a fully developed Integrity Management Program?
The integrity management rule requires operators to develop and implement an Integrity Management Program. The Integrity Management Program Framework lays the foundation for how the operator intends to develop and implement its program. As described in 192.911, the elements of an integrity management program must include several management, analytical, and operational processes. OPS expects that a number of operators may not have fully developed these aspects of their integrity management programs at this time. OPS also recognizes that making significant, fundamental changes in operator management, analytical, and operational processes and implementing new analytical tools takes time. As such, OPS does not expect operators to have fully mature integrity management programs by the initial deadline (December 17, 2004). As described in 192.907, OPS expects the integrity management framework to describe how an operator currently addresses each element of an integrity management program, an
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