Field Operations / Compliance

Pipeline Integrity Management: The Baseline Assessment That Finds the Weak Pipe

Integrity management is a plan with a baseline, an assessment schedule, and a repair priority. Gathering lines are moving under the same scrutiny.

Marcus Hale Updated 2026-08-30 4 min read

The program the rules require

Under 49 CFR 195.452, operators of hazardous liquid pipelines that could affect High Consequence Areas must have an integrity management program. The program must include a plan to carry out baseline assessments of the line pipe, and it must address each element of integrity management, including continual integrity assessment. This is not a one-time survey. The rule builds a cycle: assess, find, fix, reassess. The same discipline applies to gas transmission pipelines under Part 192 Subpart O, which sets integrity management requirements for those systems.

The baseline is the starting truth

The baseline assessment establishes what the pipe actually looks like today: wall thickness, defects, corrosion, and anomalies, usually found through in-line inspection, hydrostatic testing, or direct assessment. Without the baseline, every later decision is guesswork, because the operator has no picture of the pipe's real condition. The assessment schedule then keeps the picture current, and the reassessment interval is tied to the risk the pipe presents. The discipline matters most for lines that cross populated areas, waterways, and other High Consequence Areas, where a failure moves from a cost to a consequence.

Gathering lines are no longer a loophole

Gathering lines have their own classification rules under 49 CFR 192.9, and PHMSA has expanded federal oversight of gathering lines in recent rulemakings. The old assumption that gathering lines escape integrity scrutiny is fading. Operators and the contractors who maintain these lines now need the same records the transmission side keeps: assessment results, anomaly lists, repair dates, and the reasoning behind repair priorities. When a condition is discovered, 195.452(h) requires the operator to correct it, considering the risk to people, property, and the environment in prioritizing the repair.

Integrity management connects to the ground truth of field operations: ground disturbance tickets, remote monitoring, and plug and abandonment planning. If assessment dates and repair records live in separate systems from the field work, an operations audit will show which pipelines have a current picture and which are running on an old one.