The latest from the silvertooth team

January 20, 2017

PHMSA to Release Anticipated Final Rule on Monday – Sort of

Let’s get something clear… PHMSA is publishing a Final Rule on Monday (January 23rd), but it does NOT include the OQ portion that will have the biggest impact on the industry. There are 132 pages in the new PHMSA Final Rule. Here are the most significant items included in this new Final Rule: Accident & Incident Reporting – Notify the National Response Center within one hour after confirmed discovery of a pipeline incident or accident (verify or correct this discovery with product loss estimates within 48 hours). Drug & Alcohol Electronic Reporting – Requiring operators electronic reporting for anti-drug testing results in 199.119 and alcohol testing results required in 199.229. Drug & Alcohol Post Accident Testing – PHMSA modification of 199.105 and 199.225 by requiring drug testing of employees after an accident and to allow exemption from drug testing only when there is sufficient information that establishes the employee(s) had no role in the accident. Control Room Training Requirements – Addressing the NTSB recommendation to extend OQ requirements to control center staff. If you are asking yourself, “Where is the OQ portion of the rule?” We were too. After speaking with PHMSA on Thursday (1/19/2017), they confirmed that the OQ […]
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. These 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 Qualification Program sections of 49 CFR 192.805(b)(7) and 195.505(b)(7) requiring operators to establish and maintain and Management of Change Program. The following information summarizes PHMSA’s 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. PHMSA’s intent with the addition of the new requirement is to ensure personnel are aware of changes and take appropriate action, and […]
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