Industry Evolution: Understanding the Impacts of the OQ NPRM

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.  PHMSA 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 the definition of a covered task, new OQ requirements for gathering lines and restrictions on the use of span-of-control.

In the weeks to come, EWN will cover the following topics:

July 12th – OQ NPRM: New OQ Task Requirements
Covered Task Definition
OQ for Gathering Lines
Span-of-Control

July 14th – OQ NPRM: TRAINING
Mandatory Training
Supplemental Training
Control Room Training
Evaluator Training
Training for Gathering Lines

July 19th – OQ NPRM: Records & Change Management
Management of Change
Record Keeping Requirements

July 21st – OQ NPRM: PROGRAM EFFECTIVENESS
Program Effectiveness Reviews
Program Records

July 26th – OQ NPRM: DRUG & ALCOHOL
Drug & Alcohol Requirements

July 28th – OQ NPRM & Other Updates
Incident Notification
Farm Taps
Plastic Pipes NPRM
Gas Transmission NPRM

The goal of this educational series is to help our industry understand the most impactful portions of the OQ NPRM. We urge everyone to stay tuned throughout the month and share this with as many people in our industry as possible.

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