PHMSA Pipeline Safety Compliance Analysis: 2004-2024

The Pipeline and Hazardous Materials Safety Administration (PHMSA) oversees the safety of the United States' 2.6 million miles of oil and natural gas pipelines. This report analyzes compliance issues from 2004 to 2024, focusing on excavation damage, operator qualifications (OQ), training deficiencies, and operations and maintenance (O&M) programs. Despite PHMSA's robust enforcement framework, excavation damage remains a leading cause of incidents, often due to failure to adhere to "One-Call" protocols. OQ and training deficiencies reflect systemic weaknesses, impacting operational resilience. Insufficient O&M programs contribute to pipeline failures, highlighting the need for rigorous procedural adherence. PHMSA's transparent data facilitates analysis, though limitations in aggregated excavation enforcement data persist. Sustained vigilance and a strong safety culture are critical for improving pipeline safety.

PHMSA's Role

The Pipeline and Hazardous Materials Safety Administration (PHMSA), under the U.S. Department of Transportation, ensures the safety of the nation's energy pipeline infrastructure. PHMSA employs risk-based, data-driven decisions to regulate gas distribution, gas gathering, gas transmission, hazardous liquid, and LNG facilities through inspections, incident investigations, and enforcement actions. These actions aim to drive corrective measures and enhance safety across the industry.

Scope of the Report

This report examines PHMSA's pipeline safety compliance issues from 2004 to 2024, focusing on non-safe digging, operator qualifications, training deficiencies, and O&M programs, along with associated enforcement actions and penalties.

PHMSA employs a tiered enforcement system to ensure compliance, including:

• Corrective Action Orders (CAOs): Address hazardous conditions, mandating immediate or proposed corrective actions.
• Notices of Proposed Safety Order (NOPSO): Address pipeline integrity risks, allowing operator response before finalization.
• Notices of Probable Violation (NOPV): Detail alleged violations, proposing compliance orders or penalties.
• Notices of Amendment (NOA): Direct operators to amend operational plans.
• Warning Letters (WL): Notify operators of violations, requiring corrections with follow-up inspections.

Enforcement cases, initiated post-accident or inspection, are detailed in 49 CFR Part 190, Subpart B, and are closed only after corrective actions and penalties are completed.

PHMSA's public databases provide extensive data on enforcement and incidents, including:

• Enforcement Cases (2002-Present): Details case initiation, operator, region, status, and closure.
• Incident Data: Tracks pipeline incidents since 1970, with 20-year trends by system type and incident category.
• Annual Reports: Contain operator-submitted data on pipeline characteristics, inspections, and failures.
• Cited Regulations Lookup: Allows searching enforcement cases by regulatory code.
• Electronic Reading Room: Offers access to final opinions, orders, and records since 1996.

This transparency enables stakeholders to analyze compliance trends and enforcement efficacy.

Enforcement Cases Trend

Data for 2025 is partial as of May 2025.

Overall Trends

PHMSA tracks pipeline incidents, categorizing them as "all," "serious" (fatalities or hospitalizations), or "significant" (based on cost or release volume). Between 2014 and 2024, pipelines averaged 11 deaths and 48 injuries annually from 26 incidents. Causes include corrosion, excavation damage, incorrect operation, equipment failure, material/weld failure, natural force damage, and outside force damage. Excavation damage and incorrect operation highlight preventable human-factor failures.

Non-Safe Digging

Excavation damage is a leading cause of life-threatening incidents, often due to failure to use "One-Call" systems. Violations under 49 CFR Part 196 include failure to notify, wait for marking, respect markings, or report damage. Penalties can reach $200,000 per violation per day, up to $2 million for related violations. Limited aggregated data on third-party excavation enforcement hinders comprehensive analysis.

Operator Qualifications

The OQ Rule (49 CFR Part 192, Subpart N; Part 195, Subpart G) mandates training for covered tasks. Common deficiencies include inadequate controller role definitions, poor shift handover procedures, and insufficient fatigue management, leading to NOPVs and NOAs. These reflect systemic weaknesses requiring continuous program improvement.

Training Deficiencies

Training under 49 CFR Part 172, Subpart H, requires initial and recurrent training every three years. Citations often involve inadequate fatigue management, lack of refresher training, or failure to train on abnormal operating conditions, compromising safety. Effective training is critical for operational resilience.

Operations and Maintenance

O&M programs (49 CFR Parts 191, 195) require annual reports and procedural manuals. Violations include inadequate valve maintenance, alarm management, and management of change procedures. PSMS adoption aims to enhance proactive risk management, but persistent violations indicate implementation challenges.

PHMSA's enforcement framework drives safety improvements, but persistent issues in excavation damage, OQ, training, and O&M programs highlight compliance challenges. Excavation damage underscores behavioral gaps, while OQ and training deficiencies reflect systemic weaknesses. O&M violations contribute to failures, despite PSMS adoption. PHMSA's transparent data supports analysis, but sustained vigilance and a robust safety culture are essential for enhancing pipeline safety.