Pipeline integrity programmes carry with them inherent legal issues and exposures. A meaningful integrity programme will by its very nature be self-critical, and the processes involved in evaluating pipeline systems may not only result in the positive outcome of increasing pipeline safety, but also may result in creation of data and documentation that, if misused or viewed with the wisdom critics find in hindsight, could provide a roadmap for plaintiff attorneys or government investigators to question an operator’s decisions in the event of an accident. These issues are all the more problematic when it is also recognized that there is a need for involving third parties in consulting arrangements and contracts for internal inspections, thus making data and documentation control more challenging. Also, management of documents that are provided to the government on integrity issues are subject to release to the public, raising security issues as well as putting information at increased risk of being used against the organization in enforcement or litigation proceedings.

The presentation will review the legal issues and the demands that pipeline integrity programmes place upon operators, that include data-integration and records’-retention requirements, including a discussion of how these issues and demands may result in misinterpretation and misuse of data and documents. The bases for management and company exposure will be discussed, as will the criteria used by the government for determining whether or not information within the knowledge of the company might result not only in simple liability, but also the possibility of criminal exposure.