EWN Blog

 
July 14, 2016

OQ NPRM Educational Series (Industry Evolution)

Struggling with the OQ NPRM? ┬áEWN can help. ┬áThis education series breaks down the modifications and additions laid out in the OQ NPRM. ┬áIt is paramount that our industry understands exactly what is expected and how to adapt to the modifications in this evolving industry. ┬áBelow you will find each part of the series, Industry Evolution. The Pipes Act of 2016 & Increased PHMSA Penalties Understanding the Impacts of the OQ NPRM The OQ NPRM: New OQ Task Requirements Training is Key in the OQ NPRM Maintaining a Proper OQ Channel Ensuring Program Effectiveness Updated Drug & Alcohol Testing Incident/Accident Reporting, Farm Taps & More┬á- new! STAY IN TOUCH: Are you signed up to receive this series via our newsletter? ┬áWhat are you waiting for? ┬áClick Here to Register Now (it’s free!)
July 12, 2016

Industry Evolution: New OQ Task Requirements

OPERATOR QUALIFICATION: DEFINITION OF A “COVERED TASK” 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. […]
July 8, 2016

Industry Evolution: Understanding the Impacts of the OQ NPRM

  The Pipeline and Hazardous Materials Safety Administration (PHMSA) has proposed amendments, updates and clarifications to the pipeline safety regulations to address Section 9 (Accident and Incident Notification) and Section 13 (Cost Recovery for Design Reviews) of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (2011 Act), and to certain other regulatory requirements. PHMSA has also proposed changes to the Operator Qualification (OQ) requirements and drug and alcohol testing requirements and incorporating consensus standards by reference for in-line inspection (ILI) and Stress Corrosion Cracking Direct Assessment (SCCDA) in Part 195. The public comment period for these proposed changes ended on September 8, 2015. PHMSA received comments from 35 entities. On June 1, 2016, the Gas Pipeline Advisory Committee (GPAC) and the Liquid Pipeline Advisory Committee (LPAC) met in Arlington, VA., to review several the regulations proposed by PHMSA. The GPAC and LPAC are congressionally-mandated peer review committees composed of industry, government and public pipeline safety experts that advise whether PHMSA’s proposed rules are reasonable, practical, technically feasible and cost-effective. During the month of July, EWN will explore the significant regulatory changes proposed by PHMSA in an educational series titled “Industry Evolution”, starting with their proposed core change […]
July 6, 2015

Industry Evolution: Updated Drug & Alcohol Testing

PHMSA has proposed updates to the requirements for drug and alcohol testing of employees after an accident/incident. The revised and new language in the OQ NPRM limits exemptions from post-accident/incident testing only to situations when sufficient information exists to establish that the employee(s) had no role in the accident/incident. The additional language will also require operators to document specific reasons to justify why testing was not administered and to retain such documentation for at least three years. The current PHMSA regulations require documentation of decisions not to administer a post-accident alcohol test, however, documentation for decisions not to conduct a post-accident drug test is only implied in the regulation, although it is generally followed. PHMSA’s move to expand and clarify the language for post-accident/incident drug and alcohol testing stems from the National Transportation Safety Boards (NTSB) safety recommendation to PHMSA on September 26, 2011, via NTSB Recommendation. CURRENT PHMSA REGULATIONS 199.105 Drug tests required. Each operator shall conduct the following drug tests for the presence of a prohibited drug: (b) Post-accident testing. As soon as possible but no later than 32 hours after an accident, an operator shall drug test each employee whose performance either contributed to the accident or […]
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