Let’s get something clear… PHMSA is publishing a Final Rule on Monday (January 23rd), but it does NOT include the OQ portion that will have the biggest impact on the industry. There are 132 pages in the new PHMSA Final Rule. Here are the most significant items included in this new Final Rule: Accident & Incident Reporting – Notify the National Response Center within one hour after confirmed discovery of a pipeline incident or accident (verify or correct this discovery with product loss estimates within 48 hours). Drug & Alcohol Electronic Reporting – Requiring operators electronic reporting for anti-drug testing results in 199.119 and alcohol testing results required in 199.229. Drug & Alcohol Post Accident Testing – PHMSA modification of 199.105 and 199.225 by requiring drug testing of employees after an accident and to allow exemption from drug testing only when there is sufficient information that establishes the employee(s) had no role in the accident. Control Room Training Requirements – Addressing the NTSB recommendation to extend OQ requirements to control center staff. If you are asking yourself, “Where is the OQ portion of the rule?” We were too. After speaking with PHMSA on Thursday (1/19/2017), they confirmed that the OQ […]
Are your employees qualified for Abnormal Operating Conditions? That is the question. And far too often, because of uncertainty, we hear of accidents and mishaps in the field. These incidents are costly, too. According to PHMSA.gov, in 2013, all pipeline-related incidents totaled just over $300 million in damages. Materials, welding and equipment failure, accounted for 44% of that total, resulting in over $124 million. PHMSA also collected over $1.8 million in fines relating to civil penalty actions, due to improper compliance, training, and other regulatory shortcomings. In order to ensure employees are in full compliance with both the intent and the prescriptive requirements of the OQ Rule, EWN provides both general and task specific AOCs in a variety of formats such as: General AOCs for Natural Gas, Hazardous Liquids, and Control Rooms Task Specific AOCs (23 training/evaluations and 30 evaluations only) AOC training into OQ Training Courses and Written Evaluations Incorporated AOC questions into OQ Performance Evaluations Have questions about AOCs? We can help – contact us today!
The Who? What? When? Where? Why? Behind OQ Plans The answers to the 5 W(s) constitute a formula for getting the complete story on a subject and are a popular method for investigators and journalists. Many believe that a report (or plan) can only be considered complete if it answers all 5 of these questions. Interestingly, none of these questions can be answered with a simple “yes” or “no” in order to fulfill the requirements of the formula but must contain the details. Is your OQ plan telling the complete story? Check your plan against the 5 W(s) to find out. Who? Operators who perform covered operations or maintenance activities (covered tasks) on a pipeline system. Individuals who perform covered tasks on a pipeline system. The person or persons responsible for ensuring the requirements of the plan are carried out. What? Operators must identify covered tasks being performed by company employees or contractor employees on the company pipeline. Operators must establish a plan detailing how individuals performing covered tasks are to be evaluated and confirm these individuals are prepared to react under abnormal operating conditions (AOCs) This plan should include requirements for both Operator and Contractor employees. Operators must also determine […]
In this final installment in the EWN Educational Series on the Industry Evolution, EWN will recap miscellaneous provisions of the NPRM for Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes (also known as the OQ NPRM) that are not directly related to Operator Qualifications. We will also provide a brief recap of the status of the NPRMs for the Plastic Pipes Rule and the Safety of Gas Transmission Pipelines or “Mega” Rule. INCIDENT AND ACCIDENT REPORTING The NPRM proposes to expand and clarify requires for the initial and subsequent reporting of incidents and accidents. Key highlights of these proposed changes include: Accident & Incident reporting not later than one hour after confirmed discovery Report incident and product loss Review or confirm initial report within 48 hours Defines ‘discovery’ Recommendation from Joint Session of GPAC and LPAC: PHMSA’s Pipeline Advisory Committees approved a revision to Section I. Accident and Incident Notification in the proposed OQ NPRM (PHMSA Docket No. PHMSA-2013-0163). As originally proposed by PHMSA, the rule would require operators to provide an estimate of product loss within one hour of a confirmed discovery to the National Response Center. The vote recommended moving the product […]