EWN Blog

 
June 23, 2015

Industry Evolution: Training is Key in OQ NPRM

In this edition of the EWN Educational Series on the Industry Evolution, EWN reviews the significant expansion of mandatory training requirements proposed by PHMSA. 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. Mandatory OQ Training Under current regulations, an individual may rely on his/her experience to be evaluated and qualified to perform a covered task, and training is only required “as appropriate.” Specific documentation of training is not currently a qualification or program recordkeeping requirement. PHMSA previously issued guidance on training expectations via FAQs found at: https://primis.phmsa.dot.gov/oq/faqs.htm#4 Current Regulation: 49 CFR 192.805(h) and 195.505(h). After December 16, 2004, provide training, as appropriate, to ensure that individuals performing covered tasks have the necessary knowledge and skills to perform the tasks in a manner that ensures the safe operation of pipeline facilities; The pending OQ NPRM is a significant shift to the current OQ Rule by mandating actual documented training, in addition to evaluations, for a covered task prior to an individual being allowed to perform that covered task (except when doing so under span-of-control). This requirement includes being trained […]
April 28, 2015

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┬ánew 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. Accordingly, […]
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