U. S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

1. U. S. Department of Transportation Pipeline and Hazardous Materials Safety Administration www.dot.gov

2. A “Data Driven” PHMSA – and what that means to you Kimbra Davis Western Region Gas Conference

3. Regulatory Philosophy 101 • Goals: • Safe, Clean & Reliable Energy Transportation • Objective: • Improve the Performance of this Critical Infrastructure • Overall Strategy: • Positively Impact the Performance of Individual Operators and Industry Direction • Reliance on Systematic Management for Performance • Data Driven, Deliberative Decisions on Risks • Commitment to Continuous Improvement, Collaboration, Active Communication, and Transparency • Reliance on Partnerships to Leverage Impact

4. Data Driven? • Actionable and insightful information • Widespread access to accurate data • Merge, analyze and use information to set the direction of the organization • Identify operator risks • Establish policy and strategic priorities • Manage resources effectively

5. Operator Supplied Data • Annual Reports (Infrastructure Information) • Accident and Incident Reports • Safety Related Condition Reports (near misses) • National Response Center Reports • Abandoned Pipeline Reports • Geospatial Information (NPMS) • Integrity Management Performance Measures

6. Enforcement Generated Data • Compliance (inspection results) • Procedures (O&M, etc.) • Worker competency (OQ) • Stakeholder Outreach • Asset integrity and reliability (IMP) • Corrective Action Orders • Follow-up inspections

7. Inspector Knowledge • Infrastructure Information (pipe type, age, diameter) • Personnel changes within company • Business strategies/assessment plans • Historical performance • Safety culture

8. Fundamental Truth #1 Some PHMSA data has “issues”

9. PHMSA Response • Clean-up underway…In the past year, PHMSA vetted Operator ID’s from 8,800 + to 2,600 active records • Report validation in progress (SRC’s, Accidents, etc.) • On April 3, 2008, a permanent Data Team and Data Coordinator position were established to focus on data quality and standardization. • “One-rule” forthcoming

10. One Rule • Expect NPRM late 2008/early 2009 • Improve the quality and quantity of the information collection for annual, accident, incident, and safety related condition forms • Potential actions: • Make all forms available for electronic submission • Propose change to reporting criteria to clarify causes such as “other”

11. Fundamental Truth #2 Inspector knowledge can be “stovepiped” Stovepipe: “types of collection that are managed so as to be largely distinct from one another." ….Wikipeida

12. Multiple Inspections At Corp HQ Conducted as discrete activities Multiple Inspections In the Field O&M Inspection Unit B Inspection Integrity Management Inspection Unit A Inspection Minimal “cross-talk” Some redundancies Operator Qualification Inspection Not consistently risk-based Unit X Inspection Unit Y Inspection NOT “Integrated” !!

13. Integrated Inspection • Performance is the goal • Prevention is the key strategy • Risk-based inspections offer hope for more effective, efficient, and rational inspection • Risk-based enforcement adds the emphasis as needed • What is an Integrated Inspection? • Driven by both data and experience • Shaped to fit individual operators

14. What are “integrated” inspections? • There will still be HQ inspections and field inspections. • Program Inspections will still look at corporate- and system-wide compliance efforts, procedures, and processes • Field Inspections will still look at local, site-specific compliance efforts, procedures, and records • Follow-Up Inspections will be conducted at both levels as deemed necessary

15. Modular Approach to Inspections • Multiple inspection modules are created covering different aspects of performance • A flexible approach allows inspectors to react to the facts on the ground • Inspections can be customized to probe more deeply based on the relative risks of a particular operator

16. What’s Next for II • Internal HQ/Field Team designing and modifying inspection forms • 2008: continued development and pilot testing – 6 pilots in progress (3 haz liquid, 3 natural gas) • 2009: inspector training and deployment based on pilot results

17. Fundamental Truth #3 Reporting and data generation are NOT analysis

18. New Group in PHMSA – the “PEG”

19. PEG Responsibilities • Identify and evaluate significant natural gas, LNG, and pipeline and hazardous liquid pipeline risks. • Build, maintain, and improve risk models for targeting field activities (especially inspections). • Identify significant risk factors; identify leading risk indicators; and forecast risk changes

20. Defining Risk Operator Risk

21. 4th (and final) Fundamental Truth We can all learn from our mistakes

22. Accident Investigation Positions • Just posted on www.usajobs.com • Conduct, coordinate, manage, and report comprehensive investigations of critical and nationally and regionally significant pipeline accidents. • Determine root cause and potential secondary causes • Recommendations to prevent future occurences • Collaborate on corrective action orders • Analysis for systemic trends • Contribute to advisory bulletins

23. Available at HAZMAT.DOT.GOV Used by firefighters, police, and other emergency services personnel who may be the first to arrive at the scene of a transportation incident involving a hazardous material.

24. Thank you!! Questions?? kimbra.davis@dot.gov 720-963-3160