Legal Risk Mitigation in Hydrogen Pipeline Transport through Corrective Action Order Analysis
Published in Journal of Legal Affairs and Dispute Resolution in Engineering and Construction, 2026
This study examined 76 corrective action orders (CAOs) issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) between 2011 and 2025 to better understand patterns in federal pipeline safety enforcement.
The analysis focused on identifying the main causes of enforcement actions, the types of corrective measures commonly required, and how enforcement varied across regions, materials, and failure types. Statistical analyses, including the Kruskal-Wallis H-test and two-way ANOVA, were used to evaluate differences in enforcement complexity.
The results showed that operational and technical issues were the most common focus of enforcement actions, while rupture incidents generally resulted in more extensive corrective requirements. The study also found that enforcement intensity varied depending on both pipeline material and geographic region.
Based on these findings, the study proposed a hydrogen CAO-readiness matrix to help support future safety planning and legal risk mitigation for hydrogen pipeline infrastructure.
Recommended citation: Timalsina, S., Zhang, C., Pal, U. K., Neupane, S., & Giri, M. (2026). Legal Risk Mitigation in Hydrogen Pipeline Transport through Corrective Action Order Analysis. Journal of Legal Affairs and Dispute Resolution in Engineering and Construction, 18(3). https://doi.org/10.1061/JLADAH.LADR-1586
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