This month I want to discuss PHMSA’s inspection of calibration records and the expectation that data will be quality data. First we look at the requirement to keep records.
PHMSA 49 CFR Part 192.603 (b) states: Each operator shall keep records necessary to administer the procedure established under 192.605.
Next we look at an interpretation that states that records must be authentic. Note that the Part 192 definitions in 192.3 or the Part 195 definitions in 195.2 do not define authentic. When it is not defined in pipeline code, the dictionary definition is used.
Interpretation: PI-93-047 Date: 08-05-1993 for 192.603
Under parts 191 and 192, operators may use any recordkeeping procedure that produces authentic records, without the prior approval of this agency. Although authenticity of records concerns us – for both computer and paper records – we do not believe there is sufficient need to adopt generally applicable standards governing recordkeeping procedures.
Merriam-Webster Authentic definition: authentic, genuine, bona fide mean being actually and exactly what is claimed. Authentic implies being fully trustworthy as according with fact; an authentic account of the perilous journey.
The above illustrates that PHMSA expects quality accurate records. Calibration of instruments helps ensure that records produced by those instruments are authentic records. PHMSA inspectors will check at a minimum calibration records of gas leak detectors, voltmeters used in cathodic protection surveys, half cells used in cathodic protection surveys, pressure gauges used for establishing MAOP or used for determining relief valve relief pressure and odorometers used for sniff tests.
The American Gas Association Gas Piping Technology Committee guidance for inspection/testing gas detectors is given below.
| GPTC Guide Material is available.
GPTC Guide Material for §192.171 |
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| Guidance Information |
4. The operator shall have written procedures for inspection and testing of gas detectors including establishing inspection intervals. Consideration should be given to manufacturer’s recommendations and site specific factors for establishing the inspection interval.
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When I was a PHMSA inspector, some of the common issues I saw during inspections RE calibration records included:
- Missing calibration records
- Calibration process or intervals not following operator’s O&M specified frequency or If not specified, not following manufacturer’s recommendations for recalibration intervals.
I recommend that you review your procedures RE how and when recalibration of key instruments will be done. I would be happy to help write procedures to clarify your recalibration process.
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Thank you.
Until next month….