PHMSA’s 9 OQ Inspection Protocols
As we mentioned in our last article, 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.
The purpose of Form 14 is to ensure that operators can demonstrate that their OQ programs address each protocol and describe how their program would be effective in their absence. In addition, all workers’ training and requalification progress and documentation will need to be maintained via a secure records management system. This week we will be discussing two of the elements that focus on how to handle contractor, sub-contractor and even mutual aid qualifications PHMSA Form 14 #’s 3 and 4.
PHMSA defines a covered task as an activity, identified by the operator, that: (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.
#3. Contractors Adhering to OQ Plan
Does the process require the OQ plan to be communicated to contractors and ensure that contractors are following the plan? 192.805(b); 192.805(f); 192.805(c)
#4. Contractor and Other Entity Qualification
Does the process require contractor organizations or other entities that perform covered tasks on behalf of the operator to be qualified? 192.805(b); 192.805(c); 192.855(d); 192.805(e); 192.805(f)
Each operator shall have a written qualification program that they follow. The program shall include provisions to:
(a) Ensure thorough evaluation that individuals performing covered tasks are qualified.
(b) Allow individuals that are not qualified pursuant to this subpart to perform a covered task if directed and observed by an individual that is qualified.
(c) Evaluate an individual if the operator has reason to believe that the individual’s performance of a covered task contributed to an accident or incident.
(d) Evaluate the individual if the operator has reason to believe that the individual is no longer qualified to perform a covered task.
(e) Communicate changes that affect covered tasks to individuals performing those covered tasks.
In summary, not only are Operators required to ensure the qualification of their workers, but also the workers of contractors and sub-contractors and even Mutual Aid personnel who perform tasks on their pipeline. Numbers 3 and 4 of PHMSA Form 14 address communicating effectively with contractors and other entities who perform tasks on an Operator’s pipeline. These guidelines include how to evaluate individuals, communicate changes, and confirm the qualification status of contractor or sub-contractor employees. For more information on the PHMSA Protocols visit their website at Phmsa.dot.gov.
Stay tuned for next week when we cover Element #6 and Element #7, and discuss why #5 is not included on Form 14.