Bridging boarders

Operating pipelines across international borders presents a unique challenge for energy companies. As infrastructure expands across jurisdictions, operators must ensure not only safe and reliable operations but also full compliance with two distinct regulatory frameworks: the prescriptive, rule-based system of the US under PHMSA, and the systems-oriented approach of Canada under the CER and CSA standards. Developing and maintaining effective integrity management programmes (IMPs), operations and maintenance (O&M) programmes, and damage prevention programmes that satisfy both sets of requirements is essential, but far from straightforward.

Two regulatory worlds, one operational reality

With more than 70 hazardous liquid and natural gas pipelines operating across the US-Canada border, the complexities of duel regulatory compliance are real for many operators. Operators of these cross-border pipelines must maintain the same level of safety, integrity, and operational performance as domestic systems, but with the added challenge of dual regulatory compliance and oversight.

In the US, pipeline safety is governed by PHMSA, which enforces detailed safety requirements under 49 CFR Part 192 (natural gas) and Part 195 (hazardous liquids). These regulations follow a prescriptive approach, directing Operators to take specific actions given a certain scenario. In contrast, Canadian regulations governed by CER SOR/99-294 and guided by CSA Z662, emphasises a performance-based approach allowing for engineering discretion and data driven decision making. Additionally, CSA Z662 mandates implementation of a safety loss management system (SLMS), which promotes governance, continual improvement, and organisational learning.

This divergence in regulatory philosophy means that operators must carefully assess their assets, organisational structure, and available resources to determine how best to structure their programmes. The challenge is not only technical but strategic: how do you design programmes that satisfy both jurisdictions without duplicating effort or creating confusion?

Assessing organisational fit and asset jurisdiction

Before developing or revising cross-border programmes, operators must take a critical look at their organisational structure and asset distribution. It’s essential to identify which assets fall under PHMSA versus CER oversight, determine whether personnel are shared across jurisdictions or dedicated regionally, and assess whether internal expertise is sufficient to manage dual compliance or if external support is needed.

This foundational assessment helps determine whether programmes should be maintained separately by jurisdiction or integrated into a hybrid structure that accommodates both regulatory environments. The size and maturity of the organisation, the complexity of its assets, and the nature of its stakeholder relationships all influence the optimal approach.

Separate vs hybrid programme structures

Operators typically adopt one of two strategies. Some choose to maintain entirely separate programmes for US and Canadian assets. This approach ensures clarity and direct compliance with each regulator’s expectations and is particularly effective for programmes with highly prescriptive requirements or unique stakeholder groups. Public awareness initiatives, damage prevention efforts, and emergency response plans often fall into this category, as local engagement protocols and notification systems, such as Alberta One-Call and Texas 811, can vary significantly.

Others opt for a hybrid approach, consolidating content into unified programmes while including jurisdictional annotations where requirements diverge. This method works well for programmes like IMPs and O&M. In these cases, the programme may default to the most conservative or restrictive requirements or include jurisdiction-specific content where necessary. For example, a hybrid IMP might apply the shortest inline inspection (ILI) reinspection interval across all assets or note where Canadian engineering assessments allow for extended intervals under CSA Z662.

Challenges in designing cross-border programmes

Designing safety-related management programmes – such as IMPs and O&M programmes – that span both US and Canadian jurisdictions requires thoughtful planning and a deep understanding of regulatory nuances. Operators commonly face the following questions:

How do you reconcile the regulatory approach differences between PHMSA and CSA Z662?

CSA Z662 is performance-based, allowing for engineering discretion and data-driven decision making. PHMSA regulations are more prescriptive, directing operators to take specific actions under defined scenarios. Programmes must strike a balance between these approaches while remaining compliant with both.

How do you standardise terminology across jurisdictions?

Terms like ‘Engineering Assessment’ and ‘Engineering Critical Assessment’ may appear interchangeable but carry distinct regulatory implications. Threat categories also differ between PHMSA and CSA. Standardising language within programmes is essential to ensure clarity and consistency.

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World Pipelines’ December 2025 issue

The December 2025 issue of World Pipelines explores how the global pipeline sector is adapting to the energy transition, with a strong focus on CCS readiness, digital transformation, integrity management, and operational resilience. Articles span Asia’s CCS pipeline build-out, energy market dynamics, high-precision repair and integrity solutions, repurposing existing pipelines for CO2 service, cybersecurity, autonomous operations, and the shift from traditional to cloud-based training and competency frameworks.

Read the article online at: https://www.worldpipelines.com/special-reports/02012026/bridging-boarders/