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PHMSA 9 Protocols: Form 14 (Numbers 17 & 19)

Welcome back to our overview of the PHMSA 9 Protocols/Form 14- 22 Elements.

As we have mentioned in our last few articles, PHMSA’s 9 Inspection Protocols historically were listed 1-9 with each having several sub-parts. In August of 2013, PHMSA split the nine protocols into individual sub-elements. These are now listed numerically on PHMSA’s Form 14.

In this issue, we will look at numbers 17 and 19, which cover Personnel Performance Monitoring and Program Performance and Improvement.

17. Personnel Performance Monitoring Does the program include provisions to evaluate an individual if there is reason to believe the individual is no longer qualified to perform a covered task based on: covered task performance by an individual contributed to an incident or accident; other factors affecting the performance of covered tasks?

192.805(d) (192.805(e))

192.805(d) and 192.805(e) (d) Evaluate an individual if the operator has reason to believe that the individual’s performance of a covered task contributed to an incident as defined in Part 191;(e) Evaluate an individual if the operator has reason to believe that the individual is no longer qualified to perform a covered task.

If there is an incident or accident on a jobsite, any individual who is involved or who the Operator has reason to believe may have been involved must be reevaluated before they are allowed to return to work. This will be a part of the Operator’s plan for investigating incidents.

Additionally, an Operator must include a written program for determining if an employee is no longer qualified to perform a covered task. This program should include provisions for when it will be used and what the consequences are if an individual is found to be non-qualified. These could include additional training requirements, operating under supervision for a period of time, job re-assignment, or termination.

19. Program Performance and Improvement Does the process require evaluation of the OQ program and implementation of improvements to enhance the effectiveness of the program?


192.605(a) Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted.

Element 19 addresses the conditions upon which an OQ program should be reviewed and updated. The plan administrator should continue to improve the plan by making it better, safer, and more efficient. The plan administrator must also show evidence of a periodic plan review not to exceed 15 months after the previous review.

Next time we will complete our coverage of the Elements in PHMSA’s Form 14. For more information on the Protocols or Form 14, please visit PHMSA’s website. ( If you have a suggestion for a series or story topic, please contact us at