The latest from the silvertooth team

December 9, 2016

What are AOCs: Am I Qualified or Not Qualified?

Are your employees qualified for Abnormal Operating Conditions? That is the question. And far too often, because of uncertainty, we hear of accidents and mishaps in the field. These incidents are costly, too. According to PHMSA.gov, in 2013, all pipeline-related incidents totaled just over $300 million in damages. Materials, welding and equipment failure, accounted for 44% of that total, resulting in over $124 million. PHMSA also collected over $1.8 million in fines relating to civil penalty actions, due to improper compliance, training, and other regulatory shortcomings. In order to ensure employees are in full compliance with both the intent and the prescriptive requirements of the OQ Rule, EWN provides both general and task specific AOCs in a variety of formats such as: General AOCs for Natural Gas, Hazardous Liquids, and Control Rooms Task Specific AOCs (23 training/evaluations and 30 evaluations only) AOC training into OQ Training Courses and Written Evaluations Incorporated AOC questions into OQ Performance Evaluations   Have questions about AOCs? We can help – contact us today!
November 9, 2016

5 Questions You Should Be Asking of Your OQ Plan

The Who? What? When? Where? Why? Behind OQ Plans The answers to the 5 W(s) constitute a formula for getting the complete story on a subject and are a popular method for investigators and journalists. Many believe that a report (or plan) can only be considered complete if it answers all 5 of these questions. Interestingly, none of these questions can be answered with a simple “yes” or “no” in order to fulfill the requirements of the formula but must contain the details. Is your OQ plan telling the complete story? Check your plan against the 5 W(s) to find out. Who? Operators who perform covered operations or maintenance activities (covered tasks) on a pipeline system. Individuals who perform covered tasks on a pipeline system. The person or persons responsible for ensuring the requirements of the plan are carried out. What? Operators must identify covered tasks being performed by company employees or contractor employees on the company pipeline. Operators must establish a plan detailing how individuals performing covered tasks are to be evaluated and confirm these individuals are prepared to react under abnormal operating conditions (AOCs) This plan should include requirements for both Operator and Contractor employees. Operators must also determine […]
July 18, 2016

Industry Evolution: OQ NPRM Management of Change & Recordkeeping

As PHMSA continues to promote the adoption of safety and quality management systems in the industry, the use of effective management of change (MOC) processes become even more critical for all companies. ┬áThese efforts can assist regulated operators to ensure that changes made to operation and maintenance activities, company policies, the equipment operations, and safety procedures are appropriately captured in the necessary portions of an OQ program and communicated efficiently to affected personnel. In this edition of the EWN Educational Series on the Industry Evolution, EWN reviews the proposed addition of regulations in the ΓÇÿQualification ProgramΓÇÖ sections of 49 CFR 192.805(b)(7) and 195.505(b)(7) requiring operators to establish and maintain and Management of Change Program. ┬áThe following information summarizes PHMSAΓÇÖs proposed regulatory changes, guidance provided to PHMSA by the Pipeline Advisory Committees (PACs), and comments regarding the impact of these proposed changes on the industry. MANAGEMENT OF CHANGE As proposed in the NPRM, companies will be required to establish and maintain a Management of Change program to communicate any changes to a covered task to anyone performing the task. ┬áPHMSAΓÇÖs intent with the addition of the new requirement is to ensure personnel are aware of changes and take appropriate action, and […]
July 12, 2016

Industry Evolution: New OQ Task Requirements

OPERATOR QUALIFICATION: DEFINITION OF A ΓÇ£COVERED TASKΓÇ¥ The OQ NPRM proposes to change the OQ Rule criteria for what constitutes a ‘covered task’ from the current 4-part test to a much broader 2-part test. Currently, a covered task is defined as follows: (1) Is performed on a pipeline facility; (2) Is an operations or maintenance task; (3) Is performed as a requirement of this part; and (4) Affects the operation or integrity of the pipeline. Under the pending NPRM, instead of determining a covered task by the 4-part test, PHMSA proposed to define a covered task as any maintenance, construction or emergency response task (part one) the operator identifies as affecting the safety or integrity of the pipeline facility (part two). PHMSA’s assertion is that the ‘4-part test’ omitted important tasks, such as all construction tasks on new pipelines and certain operation and maintenance tasks not specifically required under 49 CFR 192 or 195. Recommendation from the Joint GPAC and LPAC Session on June 1, 2016: PHMSA proposed a new definition of covered and emergency response tasks were not adopted by the PACs. Instead, the PACs voted to retain a modified version of the current 4-Part test for covered tasks. […]
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