{"operation":"document","citation":"PI-16-0002","title":"Bureau Veritas North America, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-07-18","effective_on":null,"summary":"PI-16-0002 response to Bureau Veritas North America, Inc. concerning 192.107, 192.113.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/Pipeline/2016/PI_16_0002.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nJUL 18 2016\nMr. Nate Chandler\nMechanical Engineer\nBureau Veritas North America, Inc.\nIndustry, Power and Utilities Group\n180 Promenade Circle, Suite 150\nSacramento, CA 95834\nDear Mr. Chandler:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nJanuary 11, 2016, you requested an interpretation of 49 CFR Part 192. You asked what the value\n·for the longitudinal joint factor (E) in 49 CFR 192.113 should be in determining the yield\nstrength (S) for steel pipe in 49 CFR 192.107.\nYou stated that Part 192 Subpart C - Pipe Design requires that the yield strength to be used in\nthe design formula in 49 CFRl 92.105 is 24,000 psi if a pipe's specification or tensile properties\nare unknown. Also, you stated the longitudinal joint factor (E) should be employed in the yield\nstrength calculation because the quality of the material properties, and the quality of joint are two\nseparate and distinct items required to be accounted for the calculation.\nYou stated that your understanding of§§ 192.107 and 192.113 is that for unknown pipe material\nwith unknown seam, the specified minimum yield strength value used in the denominator of the\npercent specified minimum yield strength calculation should be 14,400 psi (24,000 x 0.6) using\nthe E value of 0.6. Therefore, you asked if your understanding of the yield strength\ndetermination is correct.\nIn addition, PHMSA asked you to provide us with an example of the numerator and denominator\nvalues for yield strength calculations. You responded to our follow up questions on April 4,\n2016, as follows:\n1. You assumed SMYS to be 30,000 psi (no tensile data available) because the operator thinks\nthis is what it should be based on inconclusive records, from 30's, 40's, 50's or 60's or 70's,\nand has \"no tensile,\" data for these vintages to support 30ksi.\n2. You stated that the operator is unsure about wall thickness or seam joint of this vintage pipe\nbased on lack of records.\n3. You asked if the calculation for percentage SMYS is equal to= 30,000/(30,000*0.6) x 100\nusing the 30,000 psi and E factor of 0.6 in the denominator, or equal to=\n30,000/(24,000*0.6) x 100 using 24,000 psi and E factor of 0.6 in the denominator, or equal\nto= 30,000/24,000 x 100 using 24,000 psi in the denominator and without E factor?\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations ( 49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nOur responses to your April 4, 2016, email are as follows:\n1) It is incorrect to assume 30,000 psi for a pipeline without proper records and your\ncalculations would increase the percentage SMYS than decrease it. Per§ 192.107(b)(2),\na yield strength of 24,000 psi should be used for a steel pipeline with unknown yield\nstrength.\n2) When a pipe's wall thickness is unknown, the wall thickness is determined by the method\nused in § 192.109. If a pipe's longitudinal seam type is not known, it is determined using\nthe information in§ 192.113.\n3) Your values chosen for yield strength and related calculations are incorrect. Under\n§ 192.105, an accurate yield strength is required to determine the design pressure of a\npipeline. Your calculations are therefore incorrect, as you use an estimated, and\ninaccurate, SMYS within these calculations.\nIf you chose to use the§§ 192.107 and 192.113 requirements instead of tensile testing, for\nunknown pipe material, you must use 24,000 psi yield strength to determine the design pressure\nin§ 192.105. Pipe mechanical properties of diameter, wall thickness, pipe grade (strength) and\nlongitudinal seam type are then used in the design pressure formula of§ 192.105, along with any\nderating based upon operational temperatures and derating factors in§ 192.115. Ifwe can be of\nfurther assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nJanuary 11,\n2016\n49 CF\nFR 192 Requ\nuest for Inte\nerpretation\nSubpar\nrts C & L\n%S\nSMYS Calcu\nlations for U\nUnknown\nP\nPipe Materia\nal & Unknow\nwn Seam\nMr. John Ga\nale, Director\nr\nStandards a\nand Rulema\naking\nPipeline and\nd Hazardou\ns Materials\nU.S. Depart\ntment of Tra\nn\nansportation\n1200 New J\nersey Aven\nue S.E.\nWashington\nn, DC 20590\n0-0001\nEmail: John\nn.Gale@dot.g\ngov\nSafety Adm\nministration (\n(PHP-30)\nRe: Prior\nr Emails on\n12/17/2015,\nattached PD\nDF file\nDear Mr. Ga\nale:\nAt the reque\nest of one of\nf your staff m\nmembers, I h\nhave capture\ned the essen\nnce of my ea\narlier e-mail r\nrequests\nfor interpreta\nation, in this\ns abbreviated\nd letter. But\nt first, a little\nabout BV, in\nn the event y\nyou have no\not heard of\nus before no\now.\nFounded in\n1828, Burea\nu Veritas has\ns developed\na worldwide\ne network to h\nhelp busines\nsses, agencie\nes and\norganization\nns assess, att\ntain and dem\nmonstrate com\nmpliance with\nh standards\nand regulatio\nons in the fie\nelds of\nQuality, Hea\nalth & Safety,\n, Environmen\nntal and Soci\nial Accountab\nbility (QHSE-\n-SA). The co\nompany’s foc\ncus is on\nprotecting its\ns clients’ bran\nnds, assets a\nand business\ns. Our service\nes have set t\nthe standard\nd for compreh\nhensive,\nclient focuse\ned solutions t\nto environme\nental liabilities\ns, structural i\nintegrity, emp\nployee health\nh and safety\nconcerns\nas well as re\negulatory com\nmpliance issu\nues. Bureau V\nVeritas has s\nserved the q\nuality assura\nance, testing\nand\nexpediting n\needs of the p\npower gener\nration and dis\nstribution ind\nustry worldw\nwide. Working\ng in concert w\nwith\nagencies, ve\nendors, owne\ners and prog\nram manage\ners, we have\ndeveloped a\nand tailored o\nour procedur\nres to meet\nthe stringent\nt needs of ou\nur clients.\nDuring one o\nof our review\nws related to a\nan NGL (natu\nural gas line)\n) and regulat\ntions 49 CFR\nR 192 specific\ncally, we\nhave discove\nered a point\nof concern a\nand request a\na formal inter\nrpretation of t\nthe applicab\nle sections o\nof the code.\nOur clarificat\ntion is specif\nfically addres\nssed to the re\necommended\nd calculation\ns for %SMYS\nS. This is us\nsually some\ncalculated h\noop stress a\nt a particular\nr pressure (n\numerator) div\nvided by SM\nMYS (demonin\nnator) in term\nms resoled\nin terms of p\npercent. The\nspecific con\nncern is what\nt value to use\ne for the deno\nominator of t\nthe %SMYS\ncalculation\nas it applies\nto “unknown\nn pipe materi\nal with unkno\nown seam ty\nype.”\nS\nSubpart C-P\nipe Design, i\nis very clear\nthat 24,000\npsi and a joi\nnt factor, E,\nare to be em\nmployed in th\ne absence\no\nof tensile dat\nta (49 CFR 1\n192.107 & 11\n13). It is clea\nar that the co\node, in this se\nection, consi\nders the qua\nality of the\nm\nmaterial prop\nperties and th\nhe quality of\njoint to be tw\nwo separate\nand distinct\nitems that ar\nre required to\no be\na\naccounted fo\nor. However\n, when calcu\nulating %SMY\nYS values fo\nor pre-1970 u\nunknown exis\nsting pipe ma\naterial with\nu\nunknown join\nnt factor for s\nstrength testi\nng, the code\ne is not clear\nspecific to th\nhe demomin\nator.\nC\nConservative\ne engineering\ng judgement\nt, and implica\nations of Sub\nbpart C, wou\nld indicate th\nhat for unkno\nown pipe\nm\nmaterial with\nunknown se\neam, the SM\nMYS value, us\nsed in the de\nenominator o\nof the %SMY\nYS calculation\nn would be\nB u r e a u\nu V e r i t as N\nN o r t h A m e r i\ni c a , I nc .\nMain: (916) 725-4\n4200\n180 Prome\nenade Circle, Suite 1\n150\nSacramento\no, CA 95834\nFax: (916) 725-8\n8242\nwww.us.bureauver\nritas.com\n\n<<<PAGE 4>>>\n\n2\n24,000 psi x\n0.6 = 14,400\n0 psi. Typica\nally, the joint\nfactor, E, is\nignored in th\nhe denomina\nator. As such\nh, 14,400\np\npsi would be\nused in the\ndenominato\nr of the %SM\nMYS calculat\ntion for unkno\nown pipe ma\naterial having\ng an\nu\nunknown sea\nam weld. Th\nhe percent di\nfference in %\n%SMYS calc\nculations, bet\ntween 24,000\n0 psi or 14,4\n400 psi,\nk\nkeeping all o\nother valuable\nes constant,\nwould be 66\n6.7%. Such a\na difference\ncould put the\ne pipe line ov\nver a 30%\no\nof SMYS thre\neshold for str\nrength testin\ng 1 hour ver\nrsus 8 hours,\n, in isolated i\nnstances, de\nepending on\nthe MAOP\nt\nthe operator\nis attempting\ng to qualify th\nhe line to.\nI\nIn summary,\nSubpart-C r\nregulations in\nndicates that\nt \"unknown\" p\npipe has two\no unknown fa\nactors, mater\nrial quality\na\nand seam we\neld quality. In\nn the absenc\nce of tensile d\ndata or quali\nty control rec\ncords, from t\nthe factory, w\nwhich, if\na\navailable, sh\nould include\nthe seam w\neld of the \"un\nnknown,\" pip\npe in questio\non, the most c\nconservative\ne of both\nf\nfactors shoul\nld be employ\nyed (e.g; 24,0\n000 psi and\nE=0.6). In co\nontrast, new\npipe is tensi\nle tested acr\nross the\ns\nseam weld a\nand therefore\ne, SMYS for n\nnew pipe wo\nould include t\nthe seam we\neld joint quali\nty and the jo\noint factor,\nE\nE, would not\nbe required\nor would be\nE=1. Howev\nver, it is the p\npresumption\nthat this is n\nnot the case\nf\nfor, \"unknow\nn,\" pipe prod\nduced decad\nes earlier, an\nnd SMYS' =\nSMYS x 0.6\n6 = 24,000 x\n0.6 =14.400\npsi would\nb\nbe the conse\nervative engin\nneering appr\nroach to take\ne since the m\nmaximum %S\nSMYS is at th\nhe minimum\nd\ndenominator\nr and maximu\num numerato\nor.\n[\n[Note: It is un\nnderstood tha\nat the operat\ntor, can dete\nermine the m\ninimum and\nmaximum st\ntrength test\np\nparameters.\nTherefore, fi\ninal MAOP w\nwill be determ\nmined by test\nt. It is also kn\nnown that thi\nis may be a g\ngap in\nt\nthe CFR cod\nde, and there\nefore, an indu\nustry wide co\noncern. How\nwever, it is no\noted here as\na code inter\npretation\nc\nconcern only\ny.]\nB\nBased on wh\nhere the NGL\nL industry ha\nas come from\nm and the dire\nection the DO\nOT and NGL\nL operators w\nwish to go,\ni\nt would be h\nelpful to hav\nve an interpre\netation in this\ns matter.\nS\nSincerely,\nN\nNate Chandl\ner, PE\nM\nMechanical E\nEngineer\nI\nIndustry, Pow\nwer & Utilities\ns Group\nB\nBureau Verit\nas North Am\nmerica, Inc.\nw\nwww.us.Bure\neauVeritas.c\ncom\nw\nwww.Bureau\nuVeritas.com\nm\ncc\nc: Tewabe\nAsebe, DO\nOT\nB u r e a u\nu V e r i t as N\nN o r t h 180 Prome\nenade Circle, Suite 1\n150\nSacramento\no, CA 95834\nA m e r i\ni c a , I nc .\nMain: (916) 725-4\n4200\nFax: (916) 725-8\n8242\nwww.us.bureauver\nritas.com\n\n<<<PAGE 5>>>\n\nRequest for Formal Interpretation -Revision\nNate Chandler to: infocntr 12/17/2015 11:44 AM\nFrom: Nate Chandler/USA/VERITAS\nTo: infocntr@dot.gov\nRevised to change P (stress) to S (stress).\nTo Whom it May Concern:\nAfter calling the PHMSA Information line, I was directed to address my request, for interpretation, to this\nemail. needed.\nIf by mistake I have reached the incorrect email, please reply and help me redirect my request as\nThis email may be forward, as required, among PHMSA personnel only, at this time. I would request it\nremain confidential between PHMSA and BV, and not be posted on the PHMSA interpretation website\nuntil receipt of the interpretation, followed by a review and approval of the text to be shared with the\npublic, be obtained. I hope this request is acceptable. Corporate intellectual property and contract\nconfidentiality requirements should be honored.\nDuring an engineering review of documentation, authorized by one of our clients, our engineer raised a\npoint of concern. Since then engineers on the technical staff have been in debate about this point. We\nare now looking for a formal interpretation of the engineer's findings. It has to do with the correct way to\ncalculate %SMYS for \"unknown,\" pre-1970 pipe, or just unknown pipe. Considering that the engineer's\npresumptions have a significant effect on %SMYS results which can change from below 30% to above\nabove 40%, it's important for the operator to have a clear classification based on accurate %SMYS\ncalculations for their Integrity Management Program (IMP).\nWithout further wording, to confuse the issue, let me copy and place the findings of the engineer below:\nQuoted Findings:\n\"Per 49 CFR 192.107 and 49 CFR 192.113 clearly state that both a SMYS value of 24,000 \"and\" a\nlongitudinal joint factor of E=0.6 (E=JF for this discussion) should be used for \"unknown\" or \"pre-1970,\"\npipe in calculating Design Pressures and %SMYS. SMYS and Joint Factor, E, represent two\nindependent factors. One for unknown material quality and the other for unknown seam joint quality, as\nthe old pipe was produced from the factory and lays in the ground today.. Therefore, a conservative\nengineering approach to the %SMYS calculation would factor both into the denominator of the %SMYS\ncalculation as %SMYS = [S/(24,000 x 0.6)] x 100 = [S/14,400] x 100, versus %SMYS = [S/24,000] x100.\nIn summary, the code indicates that \"unknown\" pipe has two unknown factors, material quality and seam\nweld quality. In the absence of tensile data or quality control records, from the factory, which, if available,\nshould include the seam weld of the \"unknown,\" pipe in question, the most conservative of both factors\nshould be employed (e.g; 24,000 psi and E=0.6). In contrast, new pipe is tensile tested across the seam\nweld and therefore, SMYS for new pipe would include the seam weld joint quality and the joint factor, E,\nwould not be required or would be E=1. However, it is the engineers presumption that this is not the case\nfor, \"unknown,\" pipe and SMYS' = SMYS x 0.6 = 24,000 x 0.6 =14.400 psi.\nNote: It is understood that the operator, can determine the minimum and maximum strength test\nparameters. Therefore, final MAOP will be determined by test. It is also known that this may be an gap in\nthe CFR code, and therefore, industry wide, however, it is noted here as a code interpretation concern\nonly. \"\n\n<<<PAGE 6>>>\n\n.......End of Quoted Findings\nAlthough the regulations are clear with respect to new pipe and pressure calculations for such pipe, it is\nnot explicit as to the precise form of calculating %SMYS for \"unknown,\" pipe. The engineer's concern is\nspecifically related to \"unknown,\" pipe \"as specified by the operator,\" per CFR guidelines. The concern is\nthat material and seam welding flaws produced from the factory in the 30's, 40's and 50's may not be\nreliable, especially for operator proclaimed \"unknown,\" or non-tensile tested pipe. The \"intent,\" and\n\"spirit,\" of the code appear to be that operators, and engineers, should take the most conservative\napproach for questionable conditions not precisely or explicitly covered in the code. Operators, do not\nalways take such an approach since they are driven to optimize and maximize existing infrastructure,\nthereby minimizing costs.\nAs all good, conservative engineers do, when in doubt, they take the most conservative approach. As\nsuch, it is expected the operator will question the finding, since they historically have not employed the\nJoint Factor, E, in their denominator for %SMYS calculations relative to \"unknown,\" pipe. We are hoping\nto get an interpretation from PHMSA as supporting basis to our finding, or to remove the concern\ndepending on the PHMSA interpretation received. Typically, the operator only uses the SMYS value of\nthe unknown pipe for %SMYS calculations that ultimately, get placed into the IMP systems with respect to\n\"unknown,\" pipe. In most cases 24,000 psi is used and no joint factor is applied, or E=1 is employed, even\nfor \"unknown,\" seam welded pipe.\nThank you for your time and effort in this matter. I hope I have made our question and request clear for\nPHMSA to render a technical review and interpretation. Please call or email for further clarification., as\nneeded. An estimated time frame to render an interpretation would be helpful if it can be provided.\nThank you,\nNate Chandler , P.E.\nMechanical Engineer - Industry / Power & Utilities\nBureau Veritas North America, Inc.\n180 Promenade Circle, Suite 150\nSacramento, CA 95834\nP: 916.617.2028\nF: 916.617.2068\nD: 916.514.4519\nNate.Chandler@us.bureauveritas.com\nwww.us.bureauveritas.com/energyusa\nManagement Systems Global Certifications:\nISO 9001:2008 – Quality ● ISO 14001:2004 – Environmental ● OHSAS 18001:2007 – Health & Safety\nNOTICE:\nThis message contains confidential information.\nTo know more, please click on the following link: http://disclaimer.bureauveritas.com\n Please consider the environment before printing this e-mail\nChandler_Nate.vcf Chandler_Nate.vcf\n----- Forwarded by Nate Chandler/USA/VERITAS on 12/17/2015 11:42 AM -----\nFrom: Nate Chandler/USA/VERITAS\nTo: infocntr@dot.gov\nDate: 12/16/2015 01:57 PM\nSubject: Request for Formal Interpretation\n\n<<<PAGE 7>>>\n\nRevised for spelling, punctuation and grammar 1:55pm, 12/16/2015.\nTo Whom it May Concern:\nAfter calling the PHMSA Information line, I was directed to address my request, for interpretation, to this\nemail. needed.\nIf by mistake I have reached the incorrect email, please reply and help me redirect my request as\nThis email may be forward, as required, among PHMSA personnel only, at this time. I would request it\nremain confidential between PHMSA and BV, and not be posted on the PHMSA interpretation website\nuntil receipt of the interpretation, followed by a review and approval of the text to be shared with the\npublic, be obtained. I hope this request is acceptable. Corporate intellectual property and contract\nconfidentiality requirements should be honored.\nDuring an engineering review of documentation, authorized by one of our clients, our engineer raised a\npoint of concern. Since then engineers on the technical staff have been in debate about this point. We\nare now looking for a formal interpretation of the engineer's findings. It has to do with the correct way to\ncalculate %SMYS for \"unknown,\" pre-1970 pipe, or just unknown pipe. Considering that the engineer's\npresumptions have a significant effect on %SMYS results which can change from below 30% to above\nabove 40%, it's important for the operator to have a clear classification based on accurate %SMYS\ncalculations for their Integrity Management Program (IMP).\nWithout further wording, to confuse the issue, let me copy and place the findings of the engineer below:\nQuoted Findings:\n\"Per 49 CFR 192.107 and 49 CFR 192.113 clearly state that both a SMYS value of 24,000 \"and\" a\nlongitudinal joint factor of E=0.6 (E=JF for this discussion) should be used for \"unknown\" or \"pre-1970,\"\npipe in calculating Design Pressures and %SMYS. SMYS and Joint Factor, E, represent two\nindependent factors. One for unknown material quality and the other for unknown seam joint quality, as\nthe old pipe was produced from the factory and lays in the ground today.. Therefore, a conservative\nengineering approach to the %SMYS calculation would factor both into the denominator of the %SMYS\ncalculation as %SMYS = [P/(24,000 x 0.6)] x 100 = [P/14,400] x 100, versus %SMYS = [P/24,000] x100.\nIn summary, the code indicates that \"unknown\" pipe has two unknown factors, material quality and seam\nweld quality. In the absence of tensile data or quality control records, from the factory, which, if available,\nshould include the seam weld of the \"unknown,\" pipe in question, the most conservative of both factors\nshould be employed (e.g; 24,000 psi and E=0.6). In contrast, new pipe is tensile tested across the seam\nweld and therefore, SMYS for new pipe would include the seam weld joint quality and the joint factor, E,\nwould not be required or would be E=1. However, it is the engineers presumption that this is not the case\nfor, \"unknown,\" pipe and SMYS' = SMYS x 0.6 = 24,000 x 0.6 =14.400 psi.\nNote: It is understood that the operator, can determine the minimum and maximum strength test\nparameters. Therefore, final MAOP will be determined by test. It is also known that this may be an gap in\nthe CFR code, and therefore, industry wide, however, it is noted here as a code interpretation concern\nonly. \"\n.......End of Quoted Findings\nAlthough the regulations are clear with respect to new pipe and pressure calculations for such pipe, it is\nnot explicit as to the precise form of calculating %SMYS for \"unknown,\" pipe. The engineer's concern is\nspecifically related to \"unknown,\" pipe \"as specified by the operator,\" per CFR guidelines. The concern is\nthat material and seam welding flaws produced from the factory in the 30's, 40's and 50's may not be\nreliable, especially for operator proclaimed \"unknown,\" or non-tensile tested pipe. The \"intent,\" and\n\n<<<PAGE 8>>>\n\n\"spirit,\" of the code appear to be that operators, and engineers, should take the most conservative\napproach for questionable conditions not precisely or explicitly covered in the code. Operators, do not\nalways take such an approach since they are driven to optimize and maximize existing infrastructure,\nthereby minimizing costs.\nAs all good, conservative engineers do, when in doubt, they take the most conservative approach. As\nsuch, it is expected the operator will question the finding, since they historically have not employed the\nJoint Factor, E, in their denominator for %SMYS calculations relative to \"unknown,\" pipe. We are hoping\nto get an interpretation from PHMSA as supporting basis to our finding, or to remove the concern\ndepending on the PHMSA interpretation received. Typically, the operator only uses the SMYS value of\nthe unknown pipe for %SMYS calculations that ultimately, get placed into the IMP systems with respect to\n\"unknown,\" pipe. In most cases 24,000 psi is used and no joint factor is applied, or E=1 is employed, even\nfor \"unknown,\" seam welded pipe.\nThank you for your time and effort in this matter. I hope I have made our question and request clear for\nPHMSA to render a technical review and interpretation. Please call or email for further clarification., as\nneeded. An estimated time frame to render an interpretation would be helpful if it can be provided.\nThank you,\nNate Chandler , P.E.\nMechanical Engineer - Industry / Power & Utilities\nBureau Veritas North America, Inc.\n180 Promenade Circle, Suite 150\nSacramento, CA 95834\nP: 916.617.2028\nF: 916.617.2068\nD: 916.514.4519\nNate.Chandler@us.bureauveritas.com\nwww.us.bureauveritas.com/energyusa\nManagement Systems Global Certifications:\nISO 9001:2008 – Quality ● ISO 14001:2004 – Environmental ● OHSAS 18001:2007 – Health & Safety\nNOTICE:\nThis message contains confidential information.\nTo know more, please click on the following link: http://disclaimer.bureauveritas.com\n Please consider the environment before printing this e-mail","truncated":false,"body_characters":23055}