EWN Blog

 
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 […]
July 26, 2016

Industry Evolution: Incident/Accident Reporting, Farm Taps & More

In this final installment in the EWN Educational Series on the Industry Evolution, EWN will recap miscellaneous provisions of the NPRM for Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes (also known as the OQ NPRM) that are not directly related to Operator Qualifications. We will also provide a brief recap of the status of the NPRMs for the Plastic Pipes Rule and the Safety of Gas Transmission Pipelines or “Mega” Rule. INCIDENT AND ACCIDENT REPORTING The NPRM proposes to expand and clarify requires for the initial and subsequent reporting of incidents and accidents. Key highlights of these proposed changes include: Accident & Incident reporting not later than one hour after confirmed discovery Report incident and product loss Review or confirm initial report within 48 hours Defines ‘discovery’ Recommendation from Joint Session of GPAC and LPAC: PHMSA’s Pipeline Advisory Committees approved a revision to Section I. Accident and Incident Notification in the proposed OQ NPRM (PHMSA Docket No. PHMSA-2013-0163). As originally proposed by PHMSA, the rule would require operators to provide an estimate of product loss within one hour of a confirmed discovery to the National Response Center. The vote recommended moving the product […]
July 20, 2016

Industry Evolution: Ensuring Program Effectiveness

In the preceding editions of this EWN Educational Series, EWN has reviewed PHMSA’s proposals for a new definition of a covered task, changes to span-of-control limits, new training requirements, new evaluator selection and training requirements, a new management of change program and expanded recordkeeping requirements. These and other proposed requirements in the pending OQ NPRM are interdependent with PHMSA’s proposed requirement for an annual program effectiveness review. The program effectiveness review will require companies to maintain a very active role in their Operator Qualification program and the management of records, internal audits, and performance in the field. ANNUAL OQ PROGRAM EFFECTIVENESS REVIEW The current OQ Rule does not directly address requirements for a routine program effectiveness review. However, shortly after the original OQ Rule went into effect, PHMSA issued guidance on individual and program performance monitoring and improvement via their responses to Frequently Asked Questions found at https://primis.phmsa.dot.gov/oq/faqs.htm Current PHMSA Guidance 5.1 Are operators required to continuously monitor the performance of individuals qualified to perform covered tasks? While operators are not required to continuously monitor the performance of individuals qualified to perform covered tasks, the rule does require operators to: (a) evaluate an individual if the operator has reason to […]
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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