Today the Pipeline and Hazardous Material Safety Administration published an advisory notice in the Federal Register (77 FR 34457-34458) providing additional guidance for reporting the apparent cause of mechanical fitting failures when completing the Mechanical Fitting Failure Report Form. The need for this guidance was determined after a review of the over 8,000 reports filed for 2011.
These reports are required to be filed for any leak resulting from a failure of a mechanical fitting that results in a hazardous leak (49 CFR 192.1009). This may include failures in:
• The body of the mechanical fitting;
• Failures in the joints between the fitting and the pipe;
• Indications of leakage from the seals associated with the fitting; and
• Partial or complete separation of the pipe from the fitting.
Reporting Installation Defect Leaks
The reports are filed using PHMSA’s Mechanical Fitting Failure Report Form (PHMSA F 7100.1-2). Question 15 of that form addresses the apparent cause of the leak and provides various categories apparent causes to be used to classify the cause of the leak. This advisory notice seeks to clarify the classification to be used for failures resulting from an installation defect. PHMSA wants such failures to be reported as ‘Incorrect Operation’.
An apparent alternative is ‘Construction/Installation Defect’ as a subcategory under ‘Material or Welds/Fusion’. According to this Advisory Notice it is “PHMSA's intent to capture failure data under the ‘Material or Welds/Fusions’ leak cause category that is specific to manufacture, fabrication, material, and design defects” (77 FR 34458).
Use of Unique Leak Incident Identifiers
The Advisory Notice also advises operators that there has been a revision made to the form to allow for the use of unique leak incident identifiers developed by operators to “allow for ease of identification and prevention of duplicate filing". This revision was made at the suggestion of a number of operators.
PHMSA also reports that they have begun work on a function within the online system to allow the simultaneous submission of multiple reports. This too is in response to suggestions received from multiple operators.