On October 21st, the Senate Commerce Committee marked up and passed by voice vote the “Pipeline Integrity, Protection, and Enhancement for Leveraging Investments in the Nation’s Energy to assure Safety Act of 2025’’ or the PIPELINE Safety Act of 2025 which would reauthorize PHMSA for the next five years.  The House Transportation & Infrastructure Committee passed its legislation earlier this year. The House Energy and Commerce Committee still needs to pass its own legislation, as the next critical step.  The Senate version includes many provisions to modernize pipeline safety, streamlining pipeline oversight, improving safety of emerging gases, improving emergency response and transparency, and other miscellaneous provisions.  Click HERE  to view the Senate’s PIPELINE Safety Act of 2025.

The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations.

In October 2025, PHMSA issued 2 NOAs, 3 NOPVs, 1 PSO, and 5 WLs accompanied by $1,183,700 in proposed fines.

• $50,200 – §195.402(c)(7) – Procedure Manual
• $46,500 – §195.404(a)(3) – Maps & Records
• $116,100 – §195.404(b)(2) – Maps & Records
• $23,600 – §195.406(b) – Maximum Operating Pressure
• $7,400 – §195.428(a) – Overpressure Safety Devices
• $483,800 – §192.12(b)(2) – Underground Natural Gas Storage
• $456,100 – §192.12(c) – Underground Natural Gas Storage

Please note:

1. Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA. 
2. Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
3. A Corrective Action Order (CAO) usually addresses urgent situations arising out of an accident, spill, or other significant, immediate, or imminent safety or environmental concerns.
4. A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
5. A Notice of Proposed Safety Order (PSO) addresses pipeline integrity risks that may not constitute a hazardous facility requiring immediate corrective action (see Corrective Action Order described above), but do need to be addressed over time.
6. A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
7. Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
8. Warning Letter (WL) is an official notice by PHMSA that an operator needs to make improvements but that no further enforcement is proposed for those findings at this time.

RCP maintains a detailed database of all PHMSA enforcement actions dating back to 2007 and is routinely asked for data analysis of various enforcement actions. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.

Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course? 
RCP maintains a detailed database of all PHMSA enforcement actions and their resolution which enables us to compare and contrast individual enforcement actions to nationwide actions and trends.  We can help put things into context to ensure an effective reply for each citation.  For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.