EWN Blog

 
July 20, 2016

Industry Evolution: Ensuring Program Effectiveness

In the preceding editions of this EWN Educational Series, EWN has reviewed PHMSAΓÇÖs proposals for a new definition of a covered task, changes to span-of-control limits, new training requirements, new evaluator selection and training requirements, a new management of change program and expanded recordkeeping requirements. These and other proposed requirements in the pending OQ NPRM are interdependent with PHMSAΓÇÖs proposed requirement for an annual program effectiveness review. The program effectiveness review will require companies to maintain a very active role in their Operator Qualification program and the management of records, internal audits, and performance in the field. ANNUAL OQ PROGRAM EFFECTIVENESS REVIEW The current OQ Rule does not directly address requirements for a routine program effectiveness review. However, shortly after the original OQ Rule went into effect, PHMSA issued guidance on individual and program performance monitoring and improvement via their responses to Frequently Asked Questions found at https://primis.phmsa.dot.gov/oq/faqs.htm Current PHMSA Guidance 5.1 Are operators required to continuously monitor the performance of individuals qualified to perform covered tasks? While operators are not required to continuously monitor the performance of individuals qualified to perform covered tasks, the rule does require operators to: (a) evaluate an individual if the operator has reason to […]
July 18, 2016

Industry Evolution: OQ NPRM Management of Change & Recordkeeping

As PHMSA continues to promote the adoption of safety and quality management systems in the industry, the use of effective management of change (MOC) processes become even more critical for all companies. ┬áThese efforts can assist regulated operators to ensure that changes made to operation and maintenance activities, company policies, the equipment operations, and safety procedures are appropriately captured in the necessary portions of an OQ program and communicated efficiently to affected personnel. In this edition of the EWN Educational Series on the Industry Evolution, EWN reviews the proposed addition of regulations in the ΓÇÿQualification ProgramΓÇÖ sections of 49 CFR 192.805(b)(7) and 195.505(b)(7) requiring operators to establish and maintain and Management of Change Program. ┬áThe 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. MANAGEMENT OF CHANGE As proposed in the NPRM, companies will be required to establish and maintain a Management of Change program to communicate any changes to a covered task to anyone performing the task. ┬áPHMSAΓÇÖs intent with the addition of the new requirement is to ensure personnel are aware of changes and take appropriate action, and […]
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 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 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. […]
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