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Some Dissatisfaction With DIMP
Sher says NAPSR has not taken positions yet on any of the issues raised by the proposed rule. However, speaking for himself, and based on his informal discussions with some state regulators, he wonders what PHMSA is trying to accomplish by requiring mandatory pipe and fitting failures. He questions whether there is a national problem that needs to be addressed and, if so, what that problem is; or are there simply several localized problems that have occurred that do not warrant new reporting requirements.
Sher also has some of the same questions that Bennett does about another somewhat controversial aspect of the proposed DIMP: it’s requirement that operators establish a “Prevention through People" program. Here, an operator would be required to include in its written IM program a separate section on “Assuring Individual Performance'' in which they would identify risk management measures to evaluate and manage the contribution of human error and intervention to risk (e.g., changes to the role or expertise of people). Distribution pipelines already must comply with a significant operator qualifications rule, and drug and alcohol testing requirements. "It is unclear what additional steps they want taken," states Sher.
Bennett adds, "We thought the proposal was so vague it would cause problems at this point, plus industry believes we already address human factors through the current PHMSA requirements."