Why Build a FIMP?

---

Within the pipeline industry, many aspects of asset, risk and integrity management are governed by prescriptive code. For example, natural gas linear assets fall under subpart O and P of 49 CFR 192. Facilities or station assets may have risks that are not fully addressed by code requirements. Evaluating the specific risks for each operator in a structured manner may inform the operator of a facility related risk which requires additional risk management.

• Obsolescence management
• Pressure vessels
• Electrical systems
• Over-pressure protection
• Risks specific to rotating and reciprocating equipment
• Reliability and criticality assessments

Leveraging a structured approach for asset, risk and integrity management allows an operator to be transparent about how they define risk and are managing it. This is a powerful benefit which is often overlooked. For example, a well-documented FIMP can:

• Provide justification when requesting resources (people and/or $).  This can be internal or external, e.g. rate cases.
• A FIMP provides prioritization tools and data to decision makers managing with constrained resources.
• A FIMP can provide transparency with regulators about how risk management is blended with compliance activities.

Facilites or stations located within a pipeline, have mechanical and electrical/electronic components which can become obsolete and generate risk for an operator. A FIMP can provide structure to monitor for and mitigate risk associated with obsolete equipment. Obsolescence can be driven by lack of materials or parts for repair and/or by lack of technical support to maintain and operate the equipment.  

Obsolescence management can look very different depending on the assets. For example, a large complex facility may have obsolescence risk at a system or subsystem level, e.g. a PLC system or PLC component. Conversely, smaller and less complex assets like regulation stations may require obsolescence management across the fleet of similar assets.

A FIMP allows an operator to build a long-term plan for the assets within scope. The use of metrics and strategic objectives defined within the FIMP inform the organization of the short, mid-term and long-term priorities for the management of the assets and related risk. Long-term planning can be leveraged to show risk reduction progress over time which can be beneficial to decision makers and regulators. Additionally, strategic planning can be powerful to ensure alignment with key stakeholders, both internal and external.

A FIMP can inform operators where they may benefit from application of best practices existing within the industry. A FIMP should determine top risks and associated mitigations known within the industry. Often an emerging risk area for one operator has been an area of focus for another operator or from peer industries which can be leveraged.

A FIMP may inform an operator that they have a risk which the operator feels the industry has not sufficiently addressed prompting the operator to develop a new best practice. Recent examples in the facility space include over-pressure elimination and MAOP reconfirmation via "Method 3".

Simply stated, a FIMP is the application of PSMS principles to facilities to improve safety. Inclusion of programmatic guidance from CEPA and PRCI directs a FIMP towards those risk elements which are specific to facilities, complementing PSMS (API RP 1173) concepts.