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Navigating pipeline compliance in today’s regulatory environment means having the right people and tools in place to keep you constantly moving forward in your compliance journey. These steps can include starting a program from scratch, revising existing processes, or completing a third-party audit.

Lack of personnel, experience, or processes shouldn’t keep you from meeting internal and external compliance safety goals. Let Elemental help by providing expert experience and diverse operating backgrounds to support your success in any of the following areas.

Facility IMP and Risk

Operators with DOT facilities have undoubtedly noticed PHMSA’s increased expectations concerning facility Integrity Management (IM) and risk analysis. This new inspection and enforcement trend has created a need for a straightforward risk approach and, in some cases, standalone facility Integrity Management Program (IMP) manuals. We can also assist in facility IM development, implementation, inspection, and revision. Allow us to guide you through this developing branch of regulatory expectations.

Pipeline Safety Program Support

Written pipeline safety programs are the cornerstone of any operator’s compliance mission. It is the framework around which all compliance activities are built and the first step toward a satisfactory audit.

Elemental can guide you on developing and maintaining programs, procedures, and documentation systems that enable compliance with Federal and State regulations. Whether you are developing programs for the first time or just need a review, we have considerable experience with both gas and hazardous liquid operators of all sizes in the following areas:

 Operations and Maintenance

 Public Awareness

 Operator Qualification

 Drug and Alcohol Awareness and Misuse Prevention

 Emergency Response

 Control Room Management

 Integrity Management

o Pipeline

o Facility

o Underground Gas Storage

Safety Management Systems

With our experience across many pipeline safety topics, we are ready-made to coach you through implementation of the American Petroleum Institute’s (API) Recommended Practice (RP) 1173, Pipeline Safety Management Systems. Elemental’s team is familiar with today’s management silos and is accustomed to providing creative solutions to reestablish communication systems and foster a more efficient and comprehensive pipeline safety approach. As with any regulatory requirement, we can perform a gap analysis on the current state of your program in order to identify areas of improvement, which is an elemental component of the Plan-Do-Check-Act cycle.

Jurisdictional Analyses

Regulatory compliance begins with understanding what assets you have and who regulates those assets. Our experts can determine the beginning and ending points of where pipelines, facilities, or underground storage are regulated by either PHMSA, a State agency, or neither. From there, we can determine which pipeline safety programs apply and must be developed to meet your particular set of applicable regulations.

These documented determinations are a great compliance demonstration in any audit and can save hours of headache and internal discussion about which assets are and are not regulated.

Enquire today about some of the most challenging jurisdictional determination areas, including:

 Flowlines, gathering lines, and transmission lines

 Low stress

 Integrity Management

 Control Room Management

Contract Labor

Both new and seasoned pipeline compliance personnel are well aware that regulatory burdens can be demanding and time consuming. Many operators do not have sufficient personnel to administer compliance programs to the level they would wish. Elemental can fill this gap by acting as a temporary or contract labor team member either part time, full time, onsite, offsite, or any combination thereof. Our personnel become an extension of your existing team with the added benefit of having access to years of pipeline expertise.

Small Operator Support

Are you brand new to PHMSA regulations? Did your company recently build or acquire a DOT jurisdictional asset? Allow our experts to serve as your one-stop compliance shop. We get you completely up to speed by preparing the necessary documents, assisting in records generation, audit preparation, and performing recurring tasks. Our experts serve as an extension of your team turning each step into a training opportunity to equip you with the skills to successfully implement your own right-sized program.

Audits

Regulatory Audits
We know that audits are stressful. Our team can relieve the ever-increasing burden by helping you in all stages of preparation for, administration of, and response to Federal and State regulatory audits. We can bring peace of mind by ensuring that you have done all you can to prepare for your upcoming inspection.

Tasks might include:

 Preparation – We can review written programs, organize and review documentation, and coach personnel in inspection management

 Administration – We can be on-call or in-person during the actual audit

 Follow Up – If you find yourself with corrective actions, our experts can assist with responses to findings or creating a roadmap to correct

the issue and prevent reoccurrence

Third Party Audits
Do you need a third party audit as a health checkup on your written programs, an internal best practice, or to meet requirements for written manual review? Our clients can become inspection-ready by performing a third party audit to locate and correct potential issues before they become major concerns.

We are trained to mimic a realistic regulatory audit experience and can simulate the environment you would expect to encounter. After this mock audit is complete our experts can guide you in reviewing potential issues, developing a corrective plan, and implementing changes. This exercise is extremely beneficial to operators of any size at any stage in their compliance journey and can be customized to fit your exact needs.

Training

With new regulations, new personnel, and new industry best practices, there is a continual need for training. We develop custom and recurring courses of all kinds over a variety of subjects. Some operators simply need to comply with Control Room Management (CRM) Team Training, and others need a full pipeline orientation course. Our experts can develop materials specific to your assets and your audience and get everyone up to speed in a short space of time.

Elemental consultants have over 20 years’ experience in pipeline safety consulting for oil and gas operators of all sizes and are located in Houston, Texas and Denver, Colorado. In addition to working with the industry, our experts maintain proficiency with Department of Transportation (DOT), Pipeline and Hazardous Materials Safety Administration (PHMSA) regulatory requirements and associated State regulations, protocols, expectations, and audit practices.