Jerry Davis - Comments

As an engineer inspector for PHMSA one of the most troubling issues I observe in the 7000-1 reports completed by operators for incidents and accidents is lack of follow-up to determine a root cause. Operators are required by the rules to submit a 7000-1 report within 30 days of an accident or incident. Most operators have no problem complying with this part of the rule. But the rule also states whenever an operator receives any changes in the information reported or additions to the original report on DOT Form 7000-1, they shall file a supplemental report within 30 days. In some cases a final cause is not determined. In other cases a final determination is made as to the cause or causes but this information is not submitted to PHMSA. It is often difficult to ascertain whether these omissions are because of a lack of communication within the company or simply negligence. Regardless the rule does not require that an operator make a determination of cause and report that cause to PHMSA. This I believe is a gap in the regulations that affects all rule making. Without accurate accident and incident causal factor information it is difficult if not impossible for PHMSA to determine what the real threats are to pipeline integrity. Making rules without truly understanding the threats to pipeline integrity is a shotgun approach at best. Additionally operators should be required to determine the cause of all incidents and accidents so that they can make adjustments and changes to there programs and procedures to prevent similar accidents or incidents from occurring in the future. My proposal is to amend the rule to require operators to make a final determination of causal factor(s) related to all reportable incidents and accidents. The operator must then report the casual factor(s) to PHMSA via the Form 7000- 1. I also propose that an operator be required to provide an update to the accident or incident investigation every 30 days on a Form 7000-1 until the final cause(s) is determined. I also propose that an operator must submit with the final cause determination a plan to prevent future incidents or accidents of a similar nature from occurring in the future. Thank you for allowing me to comment. Sincerely Jerry Davis P.E. Senior Inspector/Engineer Western Region PHMSA OPS