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I've tried the url a couple of times.   Doesn't work.


Robert W Dalton, CRM
Dalton Consulting
253-229-4555
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-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of Frederic Grevin
Sent: Wednesday, May 09, 2012 6:01 AM
To: [log in to unmask]
Subject: Re: [RM] Feds Demand Accurate Gas Pipeline Safety Records

With respect to this development, I take note that, while the article (The
AP via Sacbee.com) states



"If pipeline operators can't ensure their oil and gas lines are running at
safe pressures by next year, the Pipeline and Hazardous Materials Safety
Administration underscored they could face penalties or some other type of
sanction."



and



"In a later phase, PHMSA also will direct energy companies on what to do if
they can't find records for all their pipelines, she added."



The Pipeline and Hazardous Materials Safety Administration advisory bulletin
"PHMSA Reminds Pipeline Operators to Preserve and Verify Records"  dated
2012-05-07
(http://www.phmsa.dot.gov/staticfiles//PHMSA/DownloadableFiles/Press%20Relea
ses/phmsa0912%20-%20FINALjl.pdf<http://www.phmsa.dot.gov/staticfiles/PHMSA/D
ownloadableFiles/Press%20Releases/phmsa0912%20-%20FINALjl.pdf>) does not
seem to support either of these statements. Perhaps they are derived from
other sources, not credited in the article.



In addition, the language "... could face penalties or some other type of
sanction" does not seem to give the requirement many sharp teeth on the
enforcement side.



Finally, it is hardly reassuring to hear the PHMSA hasn't yet figured out "
... what to do if [energy companies] can't find records for all their
pipelines".



I await Larry Medina's comments with bated breath.....



Fred

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212.312.3903



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