PG&E Misses Key Deadline to Produce Records

By Richard Porter-Roth posted 06-06-2011 17:31


“Pacific Gas & Electric has acknowledged it will miss a key deadline by more than a year to produce documents on the history of weld problems over the past 55 years in its gas transmission system…In a regulatory filing Tuesday, the utility admitted it will be unable to meet the deadline because the job is far more difficult than it had realized and likely will not be completed until the end of 2012. It is seeking a stay of the deadline. “

In trying to explain the lack of records and its inability to produce records, PG&E stated that it “does not maintain a single type of record specifically pertaining to gas pipe weld failures or defects before or after use," the utility said. Instead, the records are in various forms.” This is understandable in that records may be kept in paper forms such as inspection reports, structured data as in a database entry for a section of pipeline, and other data keeping systems that a large and complex company such as PG&E would have for keeping information on its pipelines.

However, the point that documents, records, and information are kept in many different places and in many different data formats,  is apparently not being made in a substantial manner as “Critics say the claims by the utility are absurd and should not be accepted by state regulators…"They should have been doing this all along - for the last 55 years they have ignored the requirements of good record keeping," said state Assemblyman Jerry Hill, D-San Mateo, whose district includes the San Bruno blastsite..."It's their job to have the records. To me, there is no excuse not to produce them. If you need the people to get this done, it's their responsibility to get it done. They have ignored this, and now they got caught…Jim Hall, a former chairman of the National Transportation Safety Board, said the filing makes it "obvious that they don't have the information that they need to run a safe system."

These are harsh words, perhaps spoken out of frustration. While I do not have any connection to PG&E and do not know their data systems, I am guessing that pulling and displaying pipeline data may be similar to a request for all the information on a company employee. To do this, you would look to the HR system (both electronic and paper HR file), file shares maintained and/or accessed by the employee, the  email system, any other systems that the employee accessed such as a SharePoint team site or a My Site page, etc. In other words, employee information is literally scattered around the company and there is no single “source document” that contains all the data about an employee.

Be that as it may, PG&E has now stated that they will not be able to provide all the requested records until December of 2012, which means that this issue will continue to be a source of public commentary, debate, and discussion – and even more chances for public disclosure of new record keeping problems. By December of 2012, PG&E will have been working this issue for over 2 years – spending money and resources to clear up the documentation issues that have been a result of an explosion in September of 2010.

It may be a good time for all companies to review not just their RM policies and procedures but to rethink them from a strategic point of view:

As the amount of electronically stored information (ESI) grows within an organization, it becomes critical to document the location, accessibility and characteristics of that information for the purposes of risk management, litigation preparedness and ediscovery. The process by which organizations catalog their information is known as data mapping.

The above quote is from the heading of an AIIM article on Data Mapping ( ). In this particular case, PG&E may have lessened the impact of records issues and they may been better able to demonstrate the complex requirements for producing records by demonstrating via a data map where documents and data reside within their company. Data Mapping is defined, in the above article, as “A data map is a listing of the organization’s ESI by category, location, and custodian or steward, including how it is stored, its accessibility, and associated retention policies and procedures.”

It may be more important than ever for companies to get a handle on the where their data resides by beginning a data map of all systems that contain ESI as well as the paper based storage locations.

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Bud Porter-Roth

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