How Familiar Are You with PHMSA’s OQ Inspection Protocols?: Element #1
In the last edition of The Report, we started our series on the PHMSA 9 OQ Inspection Protocols. If you missed it, you can catch up here. As we mentioned, PHMSA 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 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 covered tasks.
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.
1. Operator Qualification Plan and Covered Tasks
Is there an OQ plan that includes covered tasks, and the basis used for identifying covered tasks? 192.805(a) (192.801(b)
This sub-element states that each operator shall have and follow a written OQ program that includes provisions to identify covered tasks. In order to create a written OQ plan the operator may use an off the shelf program, a consultant or consortium prepared plan, or a plan developed by the operator. The OQ plan must cover all the requirements to perform covered tasks on the operator facilities and the methods used to identify those covered tasks. These requirements equally apply to contractors and third parties performing covered tasks on the pipeline.
2. Reevaluation Intervals for Covered Tasks
Does the process establish and justify requirements for reevaluation intervals for each covered task? 192.805(g)
This sub-element requires the operator to have a written OQ plan that includes provisions to identify those covered tasks and the intervals at which evaluation of the individual’s qualification is needed. Operators must determine reevaluation intervals for all covered tasks and the individual qualifications. Some covered tasks are covered by industry standards or other regulations and it is important that the operator takes this into consideration when establishing reevaluation intervals.
To recap, Element 1, Operator Qualification Plans and Covered Tasks, is set up to ensure proper qualification of employees whether operator-employed or contract. Covered tasks should also be recognized and documented. Additionally, Element 2, Reevaluation Intervals for Covered Tasks, ensures that the operator sets reevaluation time frame dependent on the complexity, criticality, and frequency of the performance of the task.
Stay tuned for the next edition of The Report where we discuss more of the Form 14 Elements. For additional information, visit PHSMA.dot.gov.