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November 21, 2014

PHMSA 9 Protocols: Form 14 (Numbers 17 & 19)

Welcome back to our overview of the PHMSA 9 Protocols/Form 14- 22 Elements. As we have mentioned in our last few articles, PHMSA’s 9 Inspection Protocols historically were listed 1-9 with each having several sub-parts. In August of 2013, PHMSA split the nine protocols into individual sub-elements. These are now listed numerically on PHMSA’s Form 14. In this issue, we will look at numbers 17 and 19, which cover Personnel Performance Monitoring and Program Performance and Improvement. 17. Personnel Performance Monitoring Does the program include provisions to evaluate an individual if there is reason to believe the individual is no longer qualified to perform a covered task based on: covered task performance by an individual contributed to an incident or accident; other factors affecting the performance of covered tasks? 192.805(d) (192.805(e)) 192.805(d) and 192.805(e) (d) Evaluate an individual if the operator has reason to believe that the individual’s performance of a covered task contributed to an incident as defined in Part 191;(e) Evaluate an individual if the operator has reason to believe that the individual is no longer qualified to perform a covered task. If there is an incident or accident on a jobsite, any individual who is involved or […]
October 2, 2014

PHMSA 9 Protocols: Form 14 – 22 Elements (Protocols 10,11 & 12)

Welcome back to our overview of the PHMSA 9 Protocols/Form 14- 22 Elements. As we mentioned in our last few articles, PHMSA’s 9 Inspection Protocols historically were listed 1-9 with each having several sub-parts. In August of 2013, PHMSA split the nine protocols into individual sub-elements. These are now listed numerically on PHMSA’s Form 14. In this issue, we will look at numbers 10, 11 and 12 which address the requirements for training and evaluating on Abnormal Operating Conditions (AOCs) and recordkeeping. 10. Abnormal Operating Conditions (detail)Does the process require: 1) individuals performing covered tasks be qualified to recognize and react to abnormal operating conditions (AOCs), 2) evaluation and qualification of individuals for their capability to recognize and react to AOCs, 3) AOCs identified as those that the individual may reasonably anticipate and appropriately react to during the performance of the covered task, and 4) established provisions for communicating AOCs for the purpose of qualifying individuals? 192.803 192.803 defines an Abnormal Operating Conditionas a condition identified by the operator that may indicate a malfunction of a component or deviation from normal operations that may: (a) Indicate a condition exceeding design limits (b) Result in a hazard(s) to persons, property, or […]
October 2, 2014

PHMSA & Ebola – What’s the Connection?

PHMSA shapes the daily activity and regulatory compliance decisions of every organization in and related to the energy industry. However, PHMSA also has a global impact capable of establishing best practices for safely handling infectious substances, such as Ebola (also known as Ebola Virus Disease or EVD) contaminated items. On June 1, 2006, PHMSA published a final ruling (effective beginning October 1, 2006) revising the classification criteria and packaging requirements to consistently align with United Nations Recommendations of Dangerous Goods for Category A and Category B Infectious Substances. Category A: Infectious Substance is defined as an infectious substance in a form capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals when exposure to it occurs. Ebola is considered a Category A: Infectious Substance. Ebola can be transmitted through infected materials, infected individuals, and infected animals. Therefore, transport of infected Personal Protective Equipment (PPE), infected individuals, and infected animals is regulated by PHMSA under 49 CFR, Parts 171-180. (To review the regulation specifics, visit www.phmsa.dot.gov) Generally, these regulations apply to the medical industry. However, individuals in other industries, such as the oil and gas industry, and the general public can greatly benefit from awareness to […]
October 2, 2014

PHMSA Protocols 8 & 9

Welcome back to our overview of the PHMSA 9 Protocols/Form 14- 22 Elements. As we mentioned in our last few articles, PHMSA’s 9 Inspection Protocols historically were listed 1-9 with each having several sub-parts. In August of 2013, PHMSA split the nine protocols into individual sub-elements. These are now listed numerically on PHMSAΓ’s Form 14. In this post, we will look at numbers 8 and 9 which address the requirements for documenting evaluation methods within your program. 8. Evaluation Methods (detail) Are evaluation methods established and documented appropriate to each covered task? (TQ.OQ.EVALMETHOD.P) (detail) 192.805(b) 192.803 192.809 (d) 192.809(e) 192.805 (b) requires that an Operator ensure through evaluation that individuals performing covered tasks are qualified. 192.809 (d) confirms that work performance history can no longer be used as the sole qualification method and 192.809(e) does not allow on-the-job performance as the sole qualification method. CFR 192.803 defines evaluation as: A process established and documented by the operator, to determine an individual’s ability to perform a covered task by any of the following: (a) Written examination (b) Oral examination (c) Work performance history review (d) Observation during (1) Performance on the job (2) On the job training (3) Simulations (e) Other […]
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