One of the Top PHMSA Violations: Failure to Follow Procedures

One of the most common reasons operators receive PHMSA findings or fines is simple: failure to follow procedures. But in most cases, it’s not because teams are ignoring requirements. It’s because procedures aren’t being executed consistently in the field. What’s even more wild is sometimes those procedures aren’t even required by code. It’s great that you want your procedures to be detail oriented, but not if those procedures don’t follow the actual process to a tee. Execution should reflect actual field practices before being formalized in documentation.

Most operators have well-written procedures that align with regulatory requirements.

The problem is:

• Procedures are hard to access in the field

• They aren’t tied to daily tasks

• There’s no visibility into whether they were actually followed

When procedures live in documents instead of workflows, execution becomes inconsistent.

Field personnel often rely on experience or memory because:

• Documents are buried in folders

• Systems are hard to navigate

• Access is limited in the field

Even when procedures exist:

• Tasks aren’t linked to specific requirements

• Teams aren’t guided step by step

• There’s no built-in accountability

Operators struggle to answer:

• Was the procedure followed?

• Who completed it?

• When was it done?

Without visibility, it’s difficult to prove compliance.

PHMSA isn’t just reviewing your procedures—they’re verifying that they are:

• Implemented as written

• Followed consistently

• Supported by documentation

You must be able to show clear alignment between:
procedure → task → record

Improving compliance starts with connecting procedures to execution.

That means:

• Making procedures easy to access in the field

• Aligning procedures directly with tasks

• Tracking completion and ownership

• Maintaining clear documentation of execution

RCP works with operators to streamline and strengthen procedures so they are:

• Clear and practical for field use

• Aligned with regulatory requirements

• Structured in a way that supports consistent execution

Well-designed procedures reduce confusion and make compliance easier to achieve. Also, in a lot of cases, you don’t want to be knocked for not following procedures that aren’t even required by code. Click here to get in touch with RCP to review your procedures.

TaskOp brings procedures into daily operations by:

• Centralizing documents in one accessible system

• Linking procedures directly to tasks and assets

• Assigning responsibility and tracking completion

• Providing real-time visibility into execution

Instead of procedures sitting on a shelf, they become part of how work gets done. Click here to get in touch with the team to take a closer look at TaskOp.

Most procedure-related findings don’t come from bad procedures—they come from inconsistent execution.

When procedures are clear, accessible, and connected to real work, operators can:

• Reduce audit risk

• Improve consistency

• Confidently demonstrate compliance