EWN Blog

 
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. […]
July 8, 2016

Industry Evolution: Understanding the Impacts of the OQ NPRM

  The Pipeline and Hazardous Materials Safety Administration (PHMSA) has proposed amendments, updates and clarifications to the pipeline safety regulations to address Section 9 (Accident and Incident Notification) and Section 13 (Cost Recovery for Design Reviews) of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (2011 Act), and to certain other regulatory requirements. ┬áPHMSA has also proposed changes to the Operator Qualification (OQ) requirements and drug and alcohol testing requirements and incorporating consensus standards by reference for in-line inspection (ILI) and Stress Corrosion Cracking Direct Assessment (SCCDA) in Part 195. The public comment period for these proposed changes ended on September 8, 2015.┬á PHMSA received comments from 35 entities.┬á On June 1, 2016, the Gas Pipeline Advisory Committee (GPAC) and the Liquid Pipeline Advisory Committee (LPAC) met in Arlington, VA., to review several the regulations proposed by PHMSA. The GPAC and LPAC are congressionally-mandated peer review committees composed of industry, government and public pipeline safety experts that advise┬áwhether PHMSA’s proposed rules are reasonable, practical, technically feasible and cost-effective. During the month of July, EWN will explore the significant regulatory changes proposed by PHMSA in an educational series titled “Industry Evolution”, starting with their proposed core change of […]
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