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Investigators found that an operator's shift-change procedure required specific information to be exchanged and required no record that it had been. The line near Marshall, Michigan ruptured at 5:58 p.m. on July 25, 2010. The control center never identified the rupture on its own, and the release was reported at 11:17 the following morning by an employee of a different company who had seen oil in a creek.¹ The National Transportation Safety Board adopted its report on July 10, 2012. It recorded that the operator "had a procedure that required specific information to be exchanged during shift changes, but no formal documentation or written record of the exchanged information was required."¹

One rule reaches the contents of a handover, and one does not

Control room management is regulated on both the gas and the hazardous liquid side. An operator must have and follow written control room management procedures, which cover a method of recording controller shift changes and any hand-over of responsibility between controllers.² Both parts require procedures for when a different controller assumes responsibility, including the content of information to be exchanged.²

The two rules part company there. The hazardous liquid section directs operators to implement section 5 of an incorporated industry practice.³ The gas section carries no such reference, so a gas operator writing a handover procedure decides for itself what belongs in the exchange. The requirement is identical and the drafting problem is not.

A regulation that dictates what a procedure must specify

One paragraph of the emergency plan rule now names the contents of a document. Each operator develops written rupture identification procedures to evaluate and identify whether a notification of potential rupture is an actual rupture event or a non-rupture event.⁴ Those procedures must, at a minimum, specify the sources of information, operational factors, and other criteria that operator personnel use to evaluate a notification of potential rupture and identify an actual rupture.⁴

Sources of information, operational factors, and criteria are three headings supplied by the rule itself. Most recordkeeping requirements name a document and stop. This one names the minimum contents of the procedure whose absence the Marshall investigation had made visible.

The manual absorbs the procedures written elsewhere

Each operator prepares and follows, for each pipeline, a manual of written procedures for operations, maintenance, and emergency response.⁵ It is reviewed and updated at intervals not exceeding 15 months but at least once each calendar year. Twelve items belong in it where applicable, among them making construction records, maps, and operating history available to appropriate operating personnel.⁵

The twelfth is easy to read past. It requires implementing the applicable control room management procedures required by the control room section.⁵ The handover procedure is therefore a component of the manual rather than a free-standing document, and it inherits the manual's review interval.

Somebody decides which portion a supervisor receives

The rule on furnishing emergency procedures is narrower than it first reads. An operator furnishes its supervisors who are responsible for emergency action a copy of that portion of the latest edition of the emergency procedures as necessary for compliance with those procedures.⁴ What the supervisor receives is not the procedures but a portion of them, selected by somebody. Whether that portion still makes sense without the paragraphs around it is a question about writing, and nothing in the rule assigns it to anyone.

Records kept for the useful life of the pipeline

Integrity management records are maintained for the useful life of the pipeline, across nine categories.⁶ One covers documents supporting the threat identification and risk assessment. Another covers documents supporting any decision, analysis, and process used to implement and evaluate each element of the baseline assessment plan and the integrity management program.⁶ The schedule prioritizing conditions found during an assessment is kept with the technical justifications for that schedule.⁶

A technical justification is prose, and its retention period is measured against the asset rather than against a fixed number of years. A separate rule keeps two filings about one event joined: where information arrives after an incident report is submitted, the supplemental report carries a clear reference by date to the original.⁷ Without that sentence the file holds two documents about one event.

What the agency has said makes a record adequate

PHMSA has published a three-part test, in the narrower setting of records establishing maximum allowable operating pressure and maximum operating pressure. Traceable records can be clearly linked to original information about a pipeline segment or facility. Verifiable records are those in which information is confirmed by other complementary, but separate, documentation. Complete records are finalized as evidenced by a signature, a date, or another appropriate marking.⁸ Those three words describe qualities of a document rather than of the data inside it, which is why an operator can hold the right information and still fail the test.

The operator decides, the manual records

We do not write procedures, set an operating pressure, classify a threat, or decide what an incident report should say. Operators, their engineers, and their regulators do that. Our part is whether the document says what those people decided. We check that a term defined in one section of a manual carries that meaning in the next. We check that a step referenced in an emergency procedure exists in the procedure it names, and that a revision date on a cover page matches the revision recorded inside. Documents arrive in confidence and stay that way.

The extract given to supervisors is the document with no owner. A manual has an author and a review interval. A portion of a manual, selected to fit a role, has neither of those and is remade every time the manual changes.