Our Principals and Associates have been involved in every aspect of the rule-making through our support of INGAA for the past five years. We have been involved in all of the developmental work performed in support of the technical basis of the ASME B31.8S supplement. We were the primary authors of B31.8S and continue support of that supplement and B31.8. We provided support in comments developed for INGAA on the proposed rule that ultimately were reflected in changes in the final version. We provided oversight and coordination services with all the supporting standards including NACE, ASNT and API. We supported INGAA in working to ensure that the FAQ’s and Protocols drafted by OPS reflect the intent of the rule and the practical aspects of pipeline operations.

We have been working with operators to build off of their existing programs and supplementing them, where appropriate, to comply with the requirements of new regulation.  In our experience, building off of the existing program better enables employees to see how these additional requirements fit into their everyday work – the work that they already do in managing damage prevention, corrosion prevention among others.

We believe that the operator as the owner of the Integrity Management Program should also be the primary author. We have been assisting operators by serving as a sounding board, providing practical advice and as a technical reviewer. We do not provide “black box solutions” or “canned” documentation. We do provide process-based approaches which enable us to work with your people to identify opportunities within your company’s culture and business environment. We have helped operators with the overall design of their program.

As programs move further along in their develoyment, we are helping to identify gaps and opportunities to help ensure the effectiveness of the program and provide continual improvement. As the programs are completed and implemented, we provide review and audit services to help insure compliance with the regulations. We also specialize in providing assistance in the development of the plans required by the program including management of change, quality assurance, performance measurement and communications.

As the programs are audited by PHMSA, we provide assistance in responding to Notices of Amendment and Notices of Probable Violation.

If you have any questions or would like more information, please contact one of our Principals: Mark Hereth at 713-294-6650 (mlh@p-pic.com) or John Zurcher at 713-494-1052 (jsz@p-pic.com).