Where the phrase comes from
On 9 September 2010 a natural gas transmission pipeline ruptured in San Bruno, California. On 3 January 2011 the US National Transportation Safety Board issued urgent recommendations asking the operator to search for the records of its pipelines, and wrote: "These records should be traceable, verifiable, and complete." (Safety Recommendation P-10-2.)
A week later, PHMSA Advisory Bulletin ADB-11-01 told operators that records used to establish maximum allowable operating pressure "shall be traceable, verifiable, and complete".
What each word means
PHMSA Advisory Bulletin ADB-2012-06, "Verification of Records" (May 2012), defines the three terms:
- Traceable: "Traceable records are those which can be clearly linked to original information about a pipeline segment or facility."
- Verifiable: "Verifiable records are those in which information is confirmed by other complementary, but separate, documentation."
- Complete: "Complete records are those in which the record is finalized as evidenced by a signature, date or other appropriate marking."
Where it sits in the regulation today
Since the gas transmission rule that took effect on 1 July 2020 (84 FR 52180), 49 CFR 192.607(b) requires that records of pipeline material properties "must be maintained for the life of the pipeline and be traceable, verifiable, and complete". Where they are not, 192.607(c) requires the operator to "develop and implement procedures for conducting nondestructive or destructive tests" to establish the missing information.
49 CFR 192.624 requires maximum allowable operating pressure to be reconfirmed where the records needed to establish it "are not traceable, verifiable, and complete" and the pipeline is in a high consequence area or a Class 3 or Class 4 location. Integrity management records themselves must be kept "for the useful life of the pipeline" (49 CFR 192.947).
These are US federal requirements for gas transmission pipelines. Other countries set their own rules, but the three words are a useful test for any integrity record, anywhere.
A test for one record
- Can you open the original source from the record itself: the mill test report, the inspection report, the dig sheet?
- Is the value confirmed by a separate document, for example an NDT report that confirms the defect depth on the dig sheet?
- Is it finalised: signed, dated, approved by a named person?
- Can you see who changed it, when and why, without the earlier version disappearing?
- Is it tied to the exact asset (segment, girth weld, chainage) so it survives re-routes and cut-outs?
How Voiwell keeps records this way
Voiwell keeps one record per asset. Files are fingerprinted, every decision carries a named person and a written reason, corrections are saved as new versions, and evidence is released only with a named approval. That design follows the same three tests. It does not make a record compliant on its own: the content still has to come from your original documents.
Sources
- NTSB, Safety Recommendations P-10-2 to P-10-4, 3 January 2011
- PHMSA Advisory Bulletin ADB-11-01, 76 FR 1504 (10 January 2011)
- PHMSA Advisory Bulletin ADB-2012-06, Verification of Records, 77 FR 26822 (7 May 2012)
- Gas transmission final rule, 84 FR 52180 (1 October 2019)
- 49 CFR 192.607, verification of pipeline material properties
- 49 CFR 192.624, MAOP reconfirmation (as amended)
- 49 CFR 192.947, integrity management records