The PHMSA has recently criticised how Integrity Management Plan (IMP) risk assessments (RAs) for pipelines are being conducted. Do you also see problems?

There is a wide range of practice among pipeline operators right now. Some RA is admittedly in need of improvement, not yet meeting the intent of the IMP regulation. However, I believe that is not due to lack of good intention, but rather incomplete understanding of risk. Risk is a relatively new concept, and is not easy to fully grasp. To address PHMSA’s concerns, we as an industry need to improve our understanding of risk and how to measure it.

What’s wrong with my relative risk model?