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 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. 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 ΓÇ£as appropriate.ΓÇ¥ 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 […]
May 21, 2015

OSHA Confined Space Construction Final Rule

On May 1, 2015, the Occupational Safety and Health Administration released a Final Rule addressing Confined Spaces in Construction (29 CFR Part 1926). This new subpart will be a comprehensive standard comprised of a permit program aimed at protecting employees from associated work hazards in confined spaces, such as atmospheric and physical. Furthermore, the Final Rule includes ΓÇ£several provisions addressing construction-specific hazards, accounts for advancements in technology, and improves enforceability of the requirements.ΓÇ¥ The new comprehensive subpart standard will replace OSHAΓÇÖs one training requirement for confined spaces. Confined spaces present a number of atmospheric and physical challenges that can be life-threatening if not addressed. Such challenges include limited or difficult exit points in case of emergency, exposure to toxic substances, electrocutions, explosions, and asphyxiation. OSHAΓÇÖs Confined Space in Construction Final Rule considers such hazardous conditions and is written with an emphasis on training and communication for the employees to save and protect lives and property. U.S. Department of Labor news materials are accessible at http://www.dol.gov. The department’s Reasonable Accommodation Resource Center converts departmental information and documents into alternative formats, which include Braille and large print. For alternative format requests, please contact the department at (202) 693-7828 (voice) or (800) 877-8339 […]
May 18, 2015

Christmas in July: EWN Water Drive a Success!

For the last few weeks, we have held a water drive for local fire departments here at EWN.  We are reaching the time of the summer when there are constant grass fires and long days for these folks and the least we can do is keep them hydrated.  We are so proud of our EWN team, with close to 40 cases donated, we are filling up all the local fire departments & volunteer fire departments as well.  EWN has also matched the donations from employees with donations to local fire departments for equipment or other needs.
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 ΓÇ£covered taskΓÇ¥ 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). PHMSAΓÇÖs assertion is that the ΓÇÿΓÇÿ4-part testΓÇÖΓÇÖ 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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