INTERSTATE 

PIPELINE 

INSPECTIONS

Additional Planning 

Could Help DOT 

Determine 

Appropriate Level of 

State Participation 

Report to Congressional Committees

May 2018

GAO-18-461

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-461, a report to 

congressional committees

May 2018

INTERSTATE PIPELINE INSPECTIONS

Additional Planning Could Help DOT Determine 

Appropriate Level of State Participation 

What GAO Found

State involvement in interstate pipeline inspections can enhance oversight, 

although the three types of agreements that the Pipeline and Hazardous 

Materials Safety Administration (PHMSA) uses to allow state participation are not 

used extensively. Annual interstate agent agreements—held by 9 states—allow 

states to participate in all inspection activities and can bolster interstate pipeline 

oversight. For instance, an inspection conducted in 2014 by New York state 

officials led to $61,900 in federal civil penalties. Temporary interstate

agreements—used in 6 states to date—allow PHMSA to request states to 

participate in specific interstate pipeline inspections. PHMSA officials said these 

agreements provide the agency greater flexibility. Some current interstate agents

GAO interviewed said that temporary interstate agreements are useful, but are 

not substitutes for interstate agent status because states do not participate in the 

full range of inspections. Finally, PHMSA as authorized by federal law recently 

established joint inspections allowing states to request to participate in interstate

inspections. However, state officials were concerned that their role is limited and 

that they must bear the full cost to participate. PHMSA officials said they intend 

to clarify the state inspector role in joint inspections and acknowledged that 

federal grants cannot be used by states to support joint inspection activities.

PHMSA allocated recently hired inspectors based on regional workload, but has 

not assessed future resource needs. From fiscal years 2012 to 2017, PHMSA’s

appropriations increased over 40 percent, allowing the agency to expand its 

inspector workforce by about 25 percent. PHMSA allocated the additional 

inspectors across the agency’s five regions based on workload. For example, 

PHMSA’s central region received a greater percentage of inspectors than other

regions to help oversee a number of new pipeline construction projects.

However, PHMSA has not planned for future workforce needs for interstate 

pipeline inspections. In particular, it has not assessed the resources and benefits

that states can provide through the three types of agreements. Leading practices

for workforce planning indicate that such forward-looking analyses are essential 

for effective workforce planning. Without such analyses, PHMSA cannot 

proactively plan for future inspection needs to ensure that federal and state 

resources are in place to provide effective oversight of interstate pipelines. 

Pipeline and Hazardous Materials Safety Administration funding and inspectors hired, 2012 –

2017

View GAO-18-461. For more information, 

contact Susan Fleming at (202) 512-2834 or 

flemings@gao.gov.

Why GAO Did This Study

PHMSA oversees the safety of 

interstate and intrastate natural gas 

and hazardous liquid pipelines. 

PHMSA certifies states to oversee

intrastate pipelines, and some states

also act as PHMSA’s “agents” to 

supplement the federal inspection 

workforce for interstate pipelines. In 

recent years PHMSA has signaled a 

move away from using interstate agent 

agreements. Recent funding increases

have enabled PHMSA to hire 

additional federal inspectors. States 

may receive annual grants to 

reimburse up to 80 percent of the cost

of their pipeline safety activities.

Congress included a provision in 

statute for GAO to review the federal 

and state responsibilities and 

resources used to inspect interstate 

pipelines. This report addresses (1) 

how state participation has affected

interstate pipeline oversight and (2) 

PHMSA’s assessment of the resources 

needed to conduct interstate pipeline 

inspections. GAO reviewed relevant 

laws and PHMSA guidance on state 

participation in these inspections; 

analyzed the most recent 6 years of 

PHMSA funding and inspector staffing 

data; and interviewed pipeline safety 

officials from PHMSA and 22 states 

selected based on level of participation 

in interstate inspections.

What GAO Recommends

PHMSA should develop a workforce 

plan for interstate pipeline inspections, 

considering, among other things, the 

additional resources and safety 

oversight that state pipeline officials 

can provide. DOT concurred with our 

recommendation and provided 

technical comments, which we 

incorporated as appropriate.
Page i GAO-18-461 Interstate Pipeline Inspection

Letter 1

Background 3

State Involvement in Interstate Pipeline Inspections, While Not 

Extensive, Can Enhance Oversight Activities 8

PHMSA Used a Regional Workload Analysis to Allocate 

Inspection Resources, but Has Not Assessed Future Resource 

Needs 13

Conclusions 16

Recommendation 16

Agency Comments 16

Appendix I States That Have Applied and Have Not Been Accepted for Interstate 

Agent Status 18

Appendix II Comments from the Department of Transportation 19

Appendix III GAO Contact and Staff Acknowledgments 20

Tables

Table 1: States selected for GAO interviews on pipeline safety 

agreements with the federal government 2

Table 2: Number of federal pipeline inspectors hired and percent 

by region, 2013 and 2017 15

Figures

Figure 1: State Participation in Interstate Pipeline Inspections by 

PHMSA Region (as of April, 2018) 7

Figure 2: PHMSA funding and hired inspectors, 2012-2017 14

Contents
Page ii GAO-18-461 Interstate Pipeline Inspection

Abbreviations

DOT Department of Transportation

PHMSA Pipeline and Hazardous Materials Safety Administration

RRIM Risk Ranking Index Model

This is a work of the U.S. government and is not subject to copyright protection in the 

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without further permission from GAO. However, because this work may contain 

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Page 1 GAO-18-461 Interstate Pipeline Inspection

441 G St. N.W.

Washington, DC 20548

May 29, 2018

The Honorable John Thune 

Chairman 

The Honorable Bill Nelson 

Ranking Member 

Committee on Commerce, Science and Transportation 

United States Senate 

The Honorable Greg Walden 

Chairman 

The Honorable Frank Pallone 

Ranking Member 

Committee on Energy and Commerce 

House of Representatives 

The Honorable Bill Shuster 

Chairman 

The Honorable Peter A. DeFazio 

Ranking Member 

Committee on Transportation and Infrastructure 

House of Representatives

The U.S. energy pipeline network is composed of over 2.7 million miles of 

pipeline transporting gas, oil, and other hazardous liquids both within 

states (intrastate) and from one state to another (interstate). Inspections 

of pipeline operator programs and facilities are key oversight activities at 

both the federal and state level. At the federal level, the Pipeline and 

Hazardous Materials Safety Administration (PHMSA) is responsible for 

developing safety-related regulations for these pipelines. In general, 

PHMSA conducts inspections and enforces regulations for interstate 

pipelines, while certified states generally oversee intrastate pipelines.1

Historically, PHMSA has also entered into agreements with some state 

pipeline safety offices to act as “agents” to supplement the federal 

inspection workforce for interstate pipelines. Over the years, however, the 

number of interstate agents has declined from 22 in 1973 to 9 today. In 

recent years, PHMSA has not accepted additional applications for 

interstate agent agreements and has signaled a move away from these 

 1 States assume that responsibility by annually certifying their state pipeline safety 

program to PHMSA.

Letter
Page 2 GAO-18-461 Interstate Pipeline Inspection

agreements. Instead, PHMSA has introduced other means of participation 

for states interested in pursuing an interstate agreement.

The Protecting our Infrastructure of Pipelines and Enhancing Safety Act 

of 2016 included a provision that GAO assess and report on the 

resources used in carrying out interstate pipeline safety agreements.2

This report examines (1) how state participation has affected interstate 

pipeline oversight and (2) PHMSA’s assessment of the resources it needs 

to conduct future interstate pipeline inspections.

To address both objectives, we reviewed relevant statutes, literature 

related to pipeline safety agreements and PHMSA guidance on state 

participation. To determine the effects of state participation in interstate 

pipeline oversight, we interviewed officials from PHMSA headquarters 

and 5 regional offices and 22 state pipeline safety offices. (See table 1). 

For our sample, we selected the following:

Table 1: States selected for GAO interviews on pipeline safety agreements with the 

federal government

Selection Criteria State

States that currently hold interstate agent 

agreements. 

Arizona, Connecticut, Iowa, Michigan, 

Minnesota, New York, Ohio, Virginia,

and Washington

States that have applied for an interstate 

agreement but have been rejected. 

Maryland, New Hampshire,

Nevada, Virginia

States that have expressed interest in, but have 

not applied for, an interstate agent agreement. 

Kentucky

States that have participated in a temporary 

interstate agent agreementa Indiana, New Hampshire, Oregon,b

Rhode Island, Virginia,c

and West Virginia

States that have left the interstate agent program 

within the past 10 years. 

California, West Virginia

States that hold intrastate certifications but have 

not participated in interstate pipeline inspections. 

These four states also varied in terms of the 

amount of interstate pipeline miles and 

geographic location. 

Illinois, New Mexico, Pennsylvania,

and Texas

Source: GAO | GAO-18-461

a

Temporary interstate agent agreements are also known as time-defined agreements

 2 Pub. L. No. 114-183, § 24, 130 Stat. 514, 530
Page 3 GAO-18-461 Interstate Pipeline Inspection

b

Oregon responded in writing.

c

Virginia is an interstate agent for hazard liquids but not for natural gas.

Our interviews provide a range of views, but are not generalizable across 

all state pipeline safety offices.

To analyze PHMSA’s assessments of interstate pipeline inspection 

resources needed, we obtained information on PHMSA’s appropriations 

and inspector staffing levels for fiscal years 2012 through 2017. We 

interviewed PHMSA officials on their data collection and verification 

procedures and based on these steps determined the data was reliable 

for our purposes. We also interviewed PHMSA officials about the 

agency’s staffing allocation analyses on inspection staff required to 

conduct interstate pipeline inspections. We assessed the extent to which 

PHMSA’s inspector staffing activities and processes met leading 

practices for workforce planning that we have identified in our prior work.3

We conducted this performance audit from June 2017 to May 2018 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The U.S. pipeline network includes both interstate and intrastate 

pipelines, the vast majority of which fall into the latter category:

• Interstate pipelines: Interstate pipelines are primarily large-volume 

transmission pipelines that carry gas or hazardous liquid–sometimes 

over hundreds of miles—to communities and large-volume users 

(e.g., factories). At the start of 2017, there were about 340,000 miles 

of interstate transmission pipelines nationwide. Newly tapped 

 3 GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GAO-04-39 (Washington, D.C.: Dec. 11, 2003). GAO, Standards for Internal Control in the 

Federal Government, GAO-14-704G (Washington, D.C.: September 2014).

Background
Page 4 GAO-18-461 Interstate Pipeline Inspection

domestic gas and oil deposits have resulted in an increase in the 

existing pipeline infrastructure to transport natural gas and oil.4

• Intrastate pipelines: Intrastate pipelines are primarily composed of gas 

distribution and some transmission pipelines that transport natural gas

pipelines to residential, commercial, and industrial customers. As of 

2015, there were about 2.2 million miles of distribution pipelines 

nationwide. In addition, an estimated 18,000 miles of federally 

regulated gathering pipelines carry natural gas or hazardous liquids 

from production areas to processing facilities where the product is 

refined before continuing in transmission pipelines.5

At the federal level, PHMSA is responsible for developing regulations for 

domestic interstate and intrastate natural gas and hazardous liquid 

pipelines. Its regulatory programs are focused on ensuring safety in the 

design, construction, operation, and maintenance of pipelines. Inspectors 

from PHMSA’s five regional offices and states are responsible for 

inspecting nearly 3,000 companies that operate 2.7 million miles of 

pipelines.

Each year, PHMSA uses its Risk Ranking Index Model (RRIM) as one 

input to determine its annual inspection priorities. RRIM categorizes each 

of the nation’s pipeline systems regulated by PHMSA into high, medium, 

and low-risk tiers. Pipeline risk are proposedbased on a combination of 

categories, such as the type of pipeline material and time since last 

inspection. PHMSA’s guidance specifies that high-risk pipelines should be 

inspected at least once every 3 years, medium-risk pipelines every 5 

years, and low-risk pipelines every 7 years. PHMSA’s goal each year is to 

 4 Interstate hazardous liquid transmission pipeline mileage increased nearly 17 percent 

since 2010. Interstate gas transmission pipeline mileage decreased by 1 percent since 

2010.

5 Only gathering pipelines close to populated areas or waterways are currently subject to 

federal requirements. In 2012, we recommended that PHMSA collect data on gathering 

pipelines to help determine whether to expand regulation of these pipelines. PHMSA 

anticipates issuing new rules in Summer, 2018 and Summer, 2019, that would expand the 

gathering pipeline mileage subject to PHMSA’s requirements. GAO, Pipeline Safety: 

Collecting Data and Sharing Information on Federally Unregulated Gathering Pipelines 

Could Help Enhance Safety, GAO-12-388 (Washington D.C.: March 22, 2012). 
Page 5 GAO-18-461 Interstate Pipeline Inspection

inspect, at a minimum, pipeline systems where the time since last 

inspection meets or exceeds the PHMSA guidance for the tier.6

Under federal pipeline safety laws,7 states may assume inspection and 

enforcement responsibilities for intrastate gas and hazardous liquid 

pipelines, which are primarily natural gas distribution pipelines. States 

assume that responsibility by annually certifying their state pipeline safety 

program to PHMSA, which PHMSA must validate. As part of a state’s 

certification, states must establish pipeline laws similar to federal pipeline 

safety regulations for intrastate pipelines, but may also impose more 

stringent pipeline safety regulations. PHMSA reimburses certified state 

agencies up to 80 percent of the total cost of operating their pipeline 

safety program through an annual grant.

PHMSA may permit certified states to participate in interstate inspections 

through three types of agreements. (See fig.1):

• Interstate agent agreement: At PHMSA’s discretion, certified states 

may enter into an interstate agent agreement for either their natural 

gas program, hazardous liquid program, or both on an annual basis. 

As of April, 2018, nine state pipeline agencies hold these agreements. 

On PHMSA’s behalf, these agencies assume inspection 

responsibilities for the range of interstate inspection activities, as 

agreed upon by PHMSA and prioritized by PHMSA during the 

agency’s annual inspection planning process. States may also 

propose and conduct additional inspections as they believe 

necessary. While state inspectors can identify violations, PHMSA is 

ultimately responsible for enforcement of interstate pipeline 

regulations and uses a range of enforcement tools from Warning 

Letters to more stringent Notices of Probable Violation with either 

proposed compliance orders or proposed civil penalties.

• Temporary interstate agreement: These agreements allow PHMSA to 

request a state that has had its certification validated by PHMSA to 

perform interstate pipeline inspections on a temporary basis. 

According to PHMSA guidelines, these agreements are used typically 

 6 In 2017, we recommended that PHMSA document the design of its RRIM and 

periodically assess the model’s effectiveness; PHMSA agreed with our recommendation 

and is currently reexamining RRIM’s key components and plans to complete the review by 

the end of 2018. GAO, Pipeline Safety: Additional Actions Could Improve Federal Use of 

Data on Pipeline Materials and Corrosion, GAO-17-639 (Washington, D.C.: Aug. 3, 2017).

7 49 U.S.C. §§ 60101-60301. 
Page 6 GAO-18-461 Interstate Pipeline Inspection

for new construction inspections, but may include assistance such as 

inspection of specific operators, witness to repairs or testing, or 

investigation of incidents. Since 2010, PHMSA has entered into 

temporary interstate agreements with six states.8

• Joint inspection: The Pipes Act of 2016 included a requirement for 

PHMSA to allow certified states to participate in the inspection of an 

interstate pipeline safety facility, if requested by the state pipeline 

safety agency.9 As of April, 2018, no states have requested to 

participate in joint inspections.

 8 PHMSA has been authorized to conduct “cooperative agreements” with states to further 

its mission since the Pipeline Safety Improvement Act of 2002 but the first temporary 

agreement was issued to Nevada in 2010.

9 Pub. L. No. 114-183, § 13, 130 Stat. 514, 524
Page 7 GAO-18-461 Interstate Pipeline Inspection

Figure 1: State Participation in Interstate Pipeline Inspections by PHMSA Region (as of April, 2018)
Page 8 GAO-18-461 Interstate Pipeline Inspection

According to PHMSA regional officials we met with, interstate agents 

conduct high-quality inspections of interstate pipelines and provide an 

important supplement to the federal inspection workforce. PHMSA 

regional officials generally agreed that interstate agents have well-trained 

staff and leverage their local knowledge to enhance interstate pipeline 

inspections within their state. Additionally, interstate agents, if authorized 

by PHMSA, may conduct inspections of interstate pipelines within their 

state more frequently than PHMSA. For instance, officials in one PHMSA

region noted that an interstate agent in their jurisdiction ensured each 

interstate operator was inspected once every 2 years, regardless of 

PHMSA’s risk ranking. Similarly, in two of 5 regions that have interstate 

agents, PHMSA regional officials stated that they needed interstate 

agents to supplement their current allocation of federal inspectors. For 

instance, in one region, PHMSA officials said that if interstate agent 

agreements were discontinued, the region would need to hire 3 to 4 

additional inspectors. In another region, officials said that interstate 

agents provided the equivalent of 5 to 10 additional inspectors. Officials in 

one PHMSA region said that, although the region could absorb the 

interstate agent workload if needed, doing so would lead to less extensive 

inspections because there would more pipelines to inspect with fewer 

federal inspectors.

Interstate agents may also enhance pipeline safety oversight within their 

state by going above and beyond the annual interstate inspection 

activities required under their agreement with PHMSA. Specifically, as 

part of the annual inspection planning process, PHMSA’s regional offices 

work with interstate agents to develop an annual inspection plan. While 

interstate agents must prioritize PHMSA’s inspection priorities, such as 

participation in new construction inspections and PHMSA-led systems 

inspections, they can also propose additional inspections of interstate 

pipelines within their state. Officials in half of the nine states with 

State Involvement in 

Interstate Pipeline 

Inspections, While 

Not Extensive, Can 

Enhance Oversight 

Activities

Interstate Agent 

Agreements Can Bolster 

Oversight in Participating 

States
Page 9 GAO-18-461 Interstate Pipeline Inspection

interstate agent agreements stated that they proposed and obtained 

PHMSA’s approval for additional interstate pipeline inspections that would 

not otherwise have been included in PHMSA’s annual inspection plan. 

For instance, PHMSA’s Western Region reported that between January 

1, 2015 and December 31, 2016 Washington State’s pipeline safety 

agency—which holds an interstate agent agreement—proposed and 

conducted 13 inspections beyond those identified in PHMSA’s inspection 

plans.

During these additional inspections conducted by interstate agents, state 

officials have identified violations of pipeline safety regulations. Some 

violations, including the four illustrative examples below, were deemed 

serious enough that PHMSA imposed civil penalties.

• In 2015, the Connecticut Department of Energy and Environmental 

Protection inspected an interstate pipeline that traverses the state. 

During the inspection, Connecticut inspectors found the pipeline 

operator had failed to employ properly qualified welders in 

constructing a section of the pipeline. As a result, PHMSA issued a 

civil penalty of $26,200 to the pipeline operator. In response to the 

findings, the operator ensured its welders were properly qualified and 

replaced the 14 welds completed by improperly qualified welders.

• In 2014, the New York Department of Public Service’s Pipeline 

Division inspected an interstate pipeline that traverses the state. 

During that inspection, New York inspectors identified violations 

related to the operator’s corrosion-control practices. Inspectors also 

found that the operator failed to prepare, and follow, a manual for 

conducting operations and maintenance activities, as well as for 

emergency response. As a result, PHMSA issued a civil penalty of 

$61,900. In response to the findings, the operator took action to 

address the corrosion control-related violations and revised its 

operations and maintenance manual.

• In 2011, the New York Department of Public Service’s Pipeline 

Division inspected an interstate pipeline that traverses the state. 

During that inspection, a New York inspector identified violations 

related to corrosion-control practices. As a result, PHMSA issued a 

civil penalty of $78,900. PHMSA also issued a Compliance Order, 

requiring the operator to remediate the identified violations, or face an 

additional civil penalty.

• In 2014, Arizona’s Corporation Commission’s Pipeline Safety Section 

inspected two interstate gas transmission lines that traverse the state. 

During the inspection, PHMSA and Arizona inspectors found that the 
Page 10 GAO-18-461 Interstate Pipeline Inspection

operator had committed probable violations by not properly odorizing 

its pipeline, and providing insufficient information to the public about 

its pipeline odorization methods.10 As a result, PHMSA issued a 

Notice of Probable Violation, proposed civil penalties totaling 

$162,700, and issued a Proposed Compliance Order.

Although state involvement in interstate inspections can enhance 

oversight, officials from almost all of our selected states that do not 

currently have an interstate agent agreement expressed little interest in 

pursuing such an agreement. Specifically, some officials in we spoke with 

plan to focus their limited resources on intrastate pipeline safety oversight 

activities. For example, although Texas has over 50,000 miles of 

interstate pipeline, officials in that state have focused exclusively on 

intrastate inspection activity, citing the heavy workload of their inspection 

staff, as well as challenges in recruiting and retaining additional 

inspectors. In another instance, California’s state pipeline safety agency 

responsible for hazardous liquid oversight voluntarily withdrew from the 

interstate agent program in 2013, citing staffing shortages stemming from 

a difficult economic climate.

Although PHMSA’s current policy stance does not prohibit the agency 

from entering into a formal interstate agent agreement if the 

circumstances warrant, the agency prefers that state agencies enter into 

temporary interstate agreements.11 PHMSA officials explained that, 

historically, PHMSA has used interstate agents to supplement federal 

inspection resources and that the current nine interstate agents 

supplement the federal workforce by approximately 10–15 inspectors. 

PHMSA officials stated that they do not intend to discontinue current 

interstate agent agreements, but due in part to a recent staff increase the 

agency has sufficient staff to meet its inspection needs without adding 

additional interstate agents. PHMSA officials also told us that intrastate 

pipelines pose the highest safety risk to states and, consequently, state 

pipeline safety agencies should focus their efforts on intrastate pipeline 

oversight rather than participating in interstate pipeline inspections. 

During the last 7 years, four states that applied for an agent agreement—

 10Odorization of pipeline gas enables detection by a person with a normal sense of smell. 

In May, 2018, GAO reported on issues related to odorizing combustible gas transported 

by pipeline. GAO, Gas Pipeline Safety: Stakeholders’ and Officials’ Views on Federal 

Odorizing Requirements, GAO-18-409 (Washington, D.C.: April 18, 2018).

11PHMSA: Guidelines for State Participating in the Pipeline Safety Program, 2017.
Page 11 GAO-18-461 Interstate Pipeline Inspection

New Hampshire, Virginia,12 Maryland, and Nevada—were not accepted 

by PHMSA for these reasons. (See app. I.) In 2013, PHMSA decided not 

to renew another state pipeline safety agency’s interstate agent 

agreement, citing the state agency’s inability to staff its program properly, 

among other things.

While temporary interstate agreements provide an opportunity to 

participate in interstate pipeline oversight, officials from some state 

agencies told us that the agreement’s limited scope and ad hoc nature 

can create obstacles to state participation. For instance, in states without 

an interstate agent agreement, state inspectors’ day-to-day work focuses 

exclusively on intrastate pipeline oversight activities. In the event PHMSA 

requested assistance with certain interstate inspections, state inspectors

may be unfamiliar with the interstate pipeline systems and operators. As a 

result, some state officials said that their inspectors may have a steep 

learning curve when conducting inspections under a temporary interstate 

agreement. However, PHMSA officials disagreed that most interstate 

agent states would have such steep learning curve because they 

currently inspect intrastate transmission pipelines; the regulations for 

interstate and intrastate pipelines are for the most part identical. Another 

obstacle some state officials identified relates to the fact that state 

pipeline safety agencies may not have sufficient inspection staff available, 

when needed, to participate in ad hoc interstate inspections.

Due to the limited state role and competing priorities, state pipeline safety 

agencies rarely enter into temporary interstate agreements. According to 

 12Virginia’s pipeline safety agency currently holds an interstate agent agreement to 

inspect hazardous liquid pipelines. Although PHMSA certifies Virginia’s pipeline safety 

agency to conduct intrastate inspections of natural gas and hazardous liquid pipelines, 

Virginia law does not provide the agency authority to inspect municipal gas systems. As a 

result, the state pipeline safety agency has entered into an agreement with PHMSA, which 

allows it to inspect municipal gas systems on PHMSA’s behalf. However, PHMSA is 

responsible for enforcement under this agreement.

PHMSA’s Other Means of 

State Participation in 

Interstate Inspections 

Have Not Been Used 

Extensively

Temporary Interstate 

Agreements
Page 12 GAO-18-461 Interstate Pipeline Inspection

officials in five of the 6 states that have that have entered into temporary 

interstate agreements, the agreements were used for limited, ad hoc 

inspections that were initiated by PHMSA. The sixth temporary interstate 

agreement was initiated by PHMSA in lieu of the Virginia pipeline safety 

agency’s 2017 application for an interstate agent agreement for natural 

gas. PHMSA offered to enter into a longer-term, temporary interstate 

agreement, which would permit the state agency to inspect the installation 

of two large interstate pipeline systems. The state agency accepted the 

temporary interstate agreement, which may be extended annually until 

the completion of the pipeline construction. To meet its new interstate 

inspection obligations, the state agency told us it hired two additional 

inspectors. According to state officials, those two inspectors will be 

dedicated to intrastate pipeline inspection, which will allow two of the 

state agency’s more experienced inspectors to conduct interstate pipeline 

inspections.

Current interstate agents do not consider temporary interstate 

agreements to be an adequate substitute for an interstate agent 

agreement. According to officials we spoke with that are currently 

interstate agents, an interstate agent agreement allows state agencies 

and their inspectors to develop a strong understanding of operators and 

pipelines within their state. A few state officials stressed that the greatest 

benefit of interstate agent status was the ability to leverage their local 

knowledge—such as the proximity and familiarity with interstate pipelines 

within their states—to allow for quick responses to public concerns and 

pipeline incidents. PHMSA officials emphasized that temporary interstate 

agreements are not intended to replicate an interstate agent agreement; 

instead, these agreements are designed to provide PHMSA the flexibility 

to request targeted, short-term assistance from state pipeline safety 

agencies with interstate pipeline inspections.

Joint inspections offer states the most limited role in interstate pipeline 

inspections and may be entered into only if the state meets certain 

conditions. In response to the requirement in the PIPES Act, PHMSA 

created joint inspections and established certain criteria for state 

participation. For instance, to ensure that participation in joint inspections 

does not compromise intrastate pipeline safety, PHMSA only allows state 

inspectors to participate if the state agency has accomplished the 

required minimum number of inspection days during the preceding 

calendar year. PHMSA also requires state agencies to bear the cost of 

participating in joint inspections—including travel and inspection time for 

the state inspectors—rather than allowing states to include this activity in 

their annual pipeline safety program grant reimbursement. According to 

Joint Inspections
Page 13 GAO-18-461 Interstate Pipeline Inspection

PHMSA officials, this requirement is designed to focus limited federal 

funds intended to support states’ intrastate pipeline safety programs.

While it is too early to know whether states will participate in joint 

inspections over the long term, no states have participated to date. 

Despite general agreement among some state pipeline safety officials 

that collaborating with PHMSA on interstate pipeline inspections could be 

beneficial, they noted that PHMSA’s criteria reduces the incentive to 

participate. For instance, a few of the state officials we spoke to generally 

expressed concern over the requirement that states bear the entire cost 

of their participation. Additionally, state officials perceive the current joint 

inspection policy as restricting state inspectors to an observer role. 

However, PHMSA officials we spoke with noted that the role of state

inspectors can vary based on the levels of training and knowledge among 

state inspectors. PHMSA officials told us they intend to clarify this role for 

states.

From fiscal year 2012 to 2017, PHMSA’s funding increased by nearly 40 

percent, allowing the agency to hire additional pipeline inspectors. 

Specifically, PHMSA’s funding increased from $110 million in fiscal year 

2012 to $154 million in fiscal year 2017.13 PHMSA’s inspection and 

enforcement division received the majority of the increased funding, 

allowing that division to hire additional staff. From fiscal year 2012 

through 2017, the number of inspectors hired increased by over 25 

percent, from 107 to 147 across the five PHMSA regions. (See fig. 2). 

 13 Funding measured in gross budget authority.

PHMSA Used a 

Regional Workload 

Analysis to Allocate 

Inspection 

Resources, but Has 

Not Assessed Future 

Resource Needs

PHMSA Has Allocated 

Increased Inspection 

Resources Based on 

Regional Workload
Page 14 GAO-18-461 Interstate Pipeline Inspection

Figure 2: PHMSA funding and hired inspectors, 2012-2017

In recent years, PHMSA has improved its analysis of the number of 

pipeline inspectors needed to address the inspection workload in each 

region. Before 2014, PHMSA allocated inspectors evenly across the 

agency’s five regions. Since 2014, PHMSA has used a regional workload 

analysis to allocate its interstate inspectors. Unlike the previous analysis, 

the regional workload analysis takes into account federal inspector 

workload, pipeline construction, and the amount of pipeline mileage in 

areas where the consequences of an accident are greater (such as 

populated and environmentally sensitive areas) to help ensure that 

PMHSA has appropriate resources in each region. For example, 

PHMSA’s central region received a greater percentage of inspectors than 

most other regions to help oversee a number of new pipeline construction 

projects. (See table 2). According to PHMSA officials, the regional 

workload analysis has resulted in a better match between workforce

staffing and needs.
Page 15 GAO-18-461 Interstate Pipeline Inspection

Table 2: Number of federal pipeline inspectors hired and percent by region, 2013 

and 2017

2013 2017

PHMSA Region Inspectors 

hired

Percent of total

hired

Inspectors 

hired

Percent of total

hired

Central 23 21% 36 24%

Eastern 15 14% 21 14%

Southern 16 15% 22 15%

Southwest 26 24% 35 24%

Western 28 26% 33 22%

Total 108 100% 147 100%

Source: GAO analysis of Pipeline and Hazardous Materials Safety Administration (PHMSA) data | GAO-18-461

While PHMSA has improved how it allocates its current inspection staff 

among the regions, the agency lacks a forward-looking workforce plan for 

interstate pipeline inspections. Workforce planning helps agencies take a 

strategic, forward-looking approach to put the right people with the right 

skills in the right places at the right time. We have previously identified 

leading practices for effective strategic workforce planning.14 These 

approaches may vary with each agency’s particular needs and mission, 

but share certain principles. These may include:

• identifying skills and competencies to fill critical workforce gaps and 

the strategies needed to recruit them;

• developing specific strategies that are tailored to address gaps in 

number, deployment, and alignment of human capital; and

• monitoring and evaluating the agency’s progress toward its human 

capital goals.

However, PHMSA has not developed a plan that systematically identifies 

the anticipated interstate pipeline inspection workload or the number of 

inspection staff needed to meet that workload. In light of the diminishing 

role that interstate agents currently provide in bolstering PHMSA’s 

inspection workforce, a plan for conducting future interstate pipeline 

inspections should also account for the reduction in resources and 

expertise state inspectors can potentially provide.

 14 See GAO-04-39. 

PHMSA Lacks an 

Inspection Workforce Plan 

That Assesses Future 

Resource Needs for 

Interstate Pipeline 

Inspections
Page 16 GAO-18-461 Interstate Pipeline Inspection

According to PHMSA officials, they have not developed a workforce plan 

for interstate pipeline inspections because the agency’s focus has been 

on allocating and training the recently hired inspectors and ensuring that 

pipeline inspections are completed. Further, the lack of an inspector 

workforce plan may be symptomatic of a wider-ranging workforce 

planning issue. A November, 2017 DOT Inspector General (IG) report 

found that PHMSA had not developed a comprehensive workforce plan 

since 2005 and recommended that PHMSA develop such a plan.15

PHMSA agreed with the recommendation and anticipates completing the 

plan by the end of December 2018. Of note, PHMSA’s 2005 workforce 

plan did not include an analysis of federal and state inspectors needed for 

interstate pipeline inspections. In the absence of a workforce plan for 

interstate inspections, PHMSA cannot proactively plan for future 

inspection needs to ensure that federal and state resources are in place 

to provide effective pipeline oversight.

PHMSA has an important role in overseeing interstate pipelines and 

operators to ensure pipeline safety, and the agency’s partnership with 

interstate agents has proven beneficial in fulfilling that role. Recent 

increases in funding have allowed PHMSA to increase its own inspection 

workforce and reduce its reliance on state agents. However, the agency 

does not have an inspection workforce plan to ensure that it is making the 

correct decisions regarding its mix of federal inspectors versus state 

resources. Therefore, it does not have reasonable assurance that it will 

be able to provide adequate oversight of interstate pipelines going 

forward.

PHMSA should develop a workforce plan for interstate pipeline 

inspections that is consistent with leading practices in workforce planning, 

which should include a consideration of the additional resources and 

safety oversight that state pipeline officials can provide.

(Recommendation 1)

We provided DOT with a draft of this report for review and comment. In its 

comments, reproduced in appendix II, the Department of Transportation 

 15 Department of Transportation Inspector General: PHMSA Has Improved Its Workforce 

Management but Planning, Hiring, and Retention Challenges Remain, (Washington, D.C.; 

Nov. 21, 2017). 

Conclusions

Recommendation

Agency Comments
Page 17 GAO-18-461 Interstate Pipeline Inspection

concurred with our recommendation. The Department of Transportation 

also provided technical comments, which we incorporated as appropriate.

We are sending copies of this report to relevant congressional 

committees, the Secretary of Transportation, and other interested parties. 

In addition, this report will also be available at no charge on GAO’s 

website at http://www.gao.gov

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or flemings@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix II.

Susan A. Fleming

Director, Physical Infrastructure Issues
Appendix I: States That Have Applied and Have 

Not Been Accepted for Interstate Agent Status

Page 18 GAO-18-461 Interstate Pipeline Inspection

In the past 7 years, four additional state pipeline safety agencies have 

applied for interstate agent agreements:

• New Hampshire: In 2014, the state legislature passed a law requiring 

the state’s pipeline safety agency to apply for interstate agent status 

on an annual basis. State pipeline safety officials cited New 

Hampshire inspectors’ local knowledge of interstate pipelines, as well 

as concerns over the frequency of PHMSA’s interstate pipeline 

inspection activity, as reasons for seeking an agreement. To date, 

PHMSA has not accepted the state agency’s annual applications for 

interstate agent status citing an increase in the federal inspection 

workforce, a preference for states to focus on intrastate pipeline 

oversight, and the ability for state agencies to participate in interstate 

inspections through other means, such as temporary interstate 

agreements.

• Virginia: In 2016, the Virginia General Assembly passed legislation 

requiring the state pipeline safety agency to apply for interstate agent 

status for natural gas. The state agency applied the following year, 

citing the need to conduct construction inspections of the Virginia 

section of two large interstate natural gas transmission pipelines. 

PHMSA did not accept the state agency’s application, citing 

increasing federal inspection resources as well the agency’s lack of 

full authority over its intrastate gas operators. Instead, PHMSA 

provided the state agency a temporary interstate agreement, 

renewable on an annual basis, to conduct the desired inspections.

• Maryland: Maryland’s pipeline safety agency applied for interstate 

agent status in 2014 in response to public concern over proposed 

construction of a new interstate pipeline. PHMSA did not accept the 

agency’s application for interstate agent status, citing an increase in 

federal resources and PHMSA’s preference that the state agency 

focus its inspection efforts on intrastate pipelines. According to state 

agency officials, public interest has waned and the state has no plans 

to reapply.

• Nevada: Nevada’s pipeline safety agency applied for interstate agent 

status in 2011. According to state pipeline safety officials, they did so 

to help retain staff, rather than as a result of pipeline safety concerns. 

PHMSA did not accept the agency’s request, citing a preference only 

to enter into new interstate agreements when additional state support 

was needed, as well as the preference for states to focus on intrastate 

pipeline facilities. According to state officials, they do not plan to 

reapply.

Appendix I: States That Have Applied and 

Have Not Been Accepted for Interstate Agent 

Status
Appendix II: Comments from the Department 

of Transportation

Page 19 GAO-18-461 Interstate Pipeline Inspection

Appendix II: Comments from the Department 

of Transportation
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 20 GAO-18-461 Interstate Pipeline Inspection

Susan Fleming, (202) 512-2834 or flemings@gao.gov

In addition to the contact named above, Sara Vermillion (Assistant 

Director), Nick Nadarski (Analyst-in-Charge), Mike Duane, David Hooper, 

Delwen Jones, Malika Rice, and Kelly Rubin made key contributions to 

this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact 

Staff 

Acknowledgements

(102072)
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