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 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 the environment.
Protocol 10 requires an individual be trained and evaluated to recognize and react to abnormal operating conditions that they may experience as they perform covered tasks. It also sets a responsibility on the Operator to establish a method for communicating AOCs so that individuals can be trained and evaluated to respond appropriately should the need arise.
11. Abnormal Operating Conditions (detail) Do records document evaluation of qualified individuals for recognition and reaction to AOCs? (TQ.OQ.ABNORMAL.R) (detail)
192.807(a) (192.807(b); 192.803)
Protocol 11 combines the AOC qualifications from Protocol 10 (192.803) and adds a recordkeeping requirement (192.807). Records of AOC training and qualification must be kept that satisfy all of the requirements stated in Protocol 12 below.
12. Qualification Records for Personnel Performing Covered Tasks (detail) Do records document the evaluation and qualifications of individuals performing covered tasks, and can the qualification of individuals performing covered tasks be verified? (TQ.OQ.RECORDS.R) (detail)
Records must be kept for a minimum of 5 years for any individual who has performed a covered task for the Operator. In addition, records must include identification of the individual, the task, the date and the methods used for evaluation at a minimum.
Each operator shall maintain records that demonstrate compliance with this subpart.
(a) Qualification records shall include:
(1) Identification of qualified individual(s)
(2) Identification of the covered tasks the individual is qualified to perform
(3) Date(s) of current qualification
(4) Qualification method(s)
(b) Records supporting an individual’s current qualification shall be maintained while the individual is performing the covered task. Records of prior qualification and records of individuals no longer performing covered tasks shall be retained for a period of five years.
In each of the next 4 issues, we will continue our coverage on the protocols until we have completed PHMSAΓÇÖs Form 14. For more information on the Protocols or Form 14, please visit PHMSA’s website.