Navigate 49 CFR Parts 190–199 with someone who helped enforce them. Compliance program audits, gap analysis, and corrective action plans tailored to your operations.
Request a Program ReviewMost compliance failures we see are not missing documents. The operator has written procedures, a qualification program, and an emergency plan. The failure is that the documents do not match what happens in the field, the records behind them are incomplete, or known problems are identified and never closed.
Compliance under 49 CFR Parts 190 through 199 is a system that has to work every day, not a binder that has to exist.
Operators must keep the records needed to administer their procedures and make maps and operating history available to the personnel who need them. Facilities that appear in billing or paper records but not in mapping systems, and system exceptions left open for years, are recurring sources of risk.
49 CFR 192.603(b) · 192.605(b)(3)Safety-critical tasks performed without a written procedure, or with a procedure no one follows, create gaps that inspections and incidents expose.
Operators remain responsible for work performed on their behalf, including qualification of personnel performing covered tasks and the accuracy of the facility information contractors rely on.
49 CFR Part 192, Subpart NOperators must investigate failures and incidents, and transmission and distribution operators must incorporate lessons learned into procedures, training, and manuals. Repeat findings on the same issue are a signal that this loop is not closing.
49 CFR 192.617Emergency plans must provide for the personnel, equipment, tools, and materials needed at the scene, and for actions directed toward protecting people first. Readiness should be tested, not assumed.
49 CFR 192.615(a)Clearpath builds each engagement around the operator's system and jurisdiction, including state rules that adopt or supplement Part 192. Our team evaluated operator and state program compliance at PHMSA.
We review your program the way a regulator would, before a regulator does.
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