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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 ΓÇ£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.ΓÇ¥ 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┬áwww.phmsa.dot.gov)┬áGenerally, 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 and […]
October 2, 2014

PHMSA Protocols 8 & 9

Welcome back to our overview of the PHMSA 9 Protocols/Form 14- 22 Elements. ┬áAs we mentioned in our last few articles, PHMSAΓÇÖs 9 Inspection┬áProtocols 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 PHMSAΓÇÖs 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. ┬á192.809 (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 individualΓÇÖs 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 forms […]
September 30, 2014

Coming Soon to Hawaii: Natural Gas

Hawaii could soon be abandoning petroleum and switching to liquefied natural gas (LNG). Hawaii officials have been searching for a way to reduce electricity costs, improve grid resiliency, and provide a low-cost alternative fuel for ground fleet and marine transportation. Imported petroleum currently supplies 90% of HawaiiΓÇÖs energy, but high oil prices are causing large electricity costs. A Hawaii residentΓÇÖs electric bills cost anywhere from 3 to 5 times higher (more than 30 cents per kilowatt-hour) than the average of mainland residents. The recent advances in LNG transportation could help provide quick relief for residents. Now that natural gas is being liquefied for transportation (LNG carrier), it can be transported great distances with reduced risk, which will allow non-gas producing areas such as Hawaii to take advantage of the benefits associated with natural gas such as reduced costs for home heating, cooling, or cooking, reduced fuel costs for transportation, steam heat production, electrical generation and manufacturing and industrial uses. This spring, Hawaii began importing limited quantities of LNG to be used as a backup fuel for its synthetic natural gas operations to increase the reliability of the gas supply to current utility customers. The goals for natural gas use in […]
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