THE SOURCE - Winter 2016 - 26

the pipeline

Major Changes to Operator
Qualification Programs on the Horizon


he Pipeline and Hazardous Materials
Safety Administration (PHMSA) has
proposed changes to its pipeline
safety regulations that will require major
changes to most operator qualification
(OQ) programs. The proposed changes
were published in the Federal Register
for comment on July 10, 2015; however,
at a recent meeting of PHMSA's Technical
Pipeline Safety Standards Committee
(TPSSC) the public got a preview of what to
expect when a final rule is issued later this
year or in 2017. The TPSSC is a committee of
industry, government and public pipeline
safety experts who advise PHMSA on
the reasonableness, cost-effectiveness,
and practicability of proposed pipeline
regulations. PHMSA is not bound by TPSSC's
recommendations, but its recommendations
carry great weight, more so than any
individual written comments submitted
during the public comment period.
Based on the discussions and
recommendations at the TPSSC meeting,
natural gas distribution and transmission
pipeline operators can expect the below
changes to their OQ programs when the final
rule comes out.
Covered Tasks
In addition to operations and
maintenance tasks, covered tasks will
now include tasks conducted during an
emergency response, construction tasks and
integrity management tasks performed on
the right-of-way. PHMSA had also proposed
to remove two parts of the four-part covered
task definition. To be a covered task, the
task must be performed on a pipeline
facility and be a specific requirement in the
pipeline safety regulations; however, the
TPSSC recommended that PHMSA keep
those provisions when it issues the final
rule. Operators will need to review current
OQ covered task lists and incorporate tasks
related to emergency response, construction
and integrity management if those tasks
meet the other three parts of the covered task

definition. Persons performing these tasks will
need to be evaluated for qualification when
the rule change takes effect.
When the OQ rule first took effect in
1999, it focused on measuring an individual's
qualification through testing and other
means rather than how that individual was
trained for the task. The word "training"
did not even appear in the OQ rules until
2004, when the rule was amended to
require an OQ program to include "training,
as appropriate, to ensure that individuals
performing covered tasks have the necessary
knowledge and skills." This has sometimes
been misinterpreted as requiring a record
of training in order for an individual to be
qualified. The TPSSC recommended that
PHMSA clarify that training records will
only be required for training provided after
these OQ rule changes take effect and
will not be retroactive. Furthermore, the
TPSSC reinforced the intent that training "as
appropriate" does not require re-training
currently qualified individuals unless changes
to procedures, equipment or technology
necessitate such training, or there is reason to
believe the individual needs re-training.
Program Effectiveness
The biggest change proposed by PHMSA
will be to require operators to conduct an
annual assessment of the effectiveness of
an operator's OQ program. The process
to measure program effectiveness must
evaluate if the qualification program is being
implemented and executed as written and
establish provisions to amend the program
to include any changes necessary to address
the findings of the program effectiveness
review. In addition, each operator must
develop program measures to determine the
effectiveness of the OQ program to minimize
human error caused by an individual's
lack of knowledge, skills and abilities to
perform covered tasks. PHMSA will require
that operators keep track of every instance


in which an individual's performance of a
covered task adversely affected the safety
or integrity of the pipeline and categorize
each occurrence into one of 13 OQ program
"deficiencies" such as "evaluation was not
conducted properly" or "individual did not
follow approved procedures." The annual
effectiveness assessment will include
reviewing these data to look for trends that
may indicate the OQ program is deficient in
one or more areas. OQ plans will have to be
revised to include a process for measuring
program effectiveness.
The final rule is expected to require
OQ plans to include criteria for who can
be an evaluator, to ensure an evaluator is
competent to assess whether an individual is
performing a task properly. Where operators
allow non-qualified individuals to perform
covered tasks under the direction and
observation of a qualified individual, the OQ
plan will have to specify a span of control
limit, such as the maximum number of
non-qualified individuals that one qualified
individual can direct and observe at the
same time. OQ plans will be required to
include a management of change process to
ensure that any changes that affect covered
tasks are communicated to individuals
performing those covered tasks.
PHMSA did not indicate how much time
it will give operators to make the necessary
changes to OQ programs once the final rule
is issued; however, given the extensive scope
of the changes one can only hope PHMSA
recognizes that implementing these changes
will take time. It will also require providers
of OQ services to adapt their products and
services to meet the new requirements. The
APGA Security and Integrity Foundation not
only provides OQ evaluations in many states
but will also soon release an online OQ plan
creation tool similar to SHRIMP. OQ plans
generated by this online tool will include all
of the provisions described above.
John Erickson is Vice President of Operations
for APGA.


Table of Contents for the Digital Edition of THE SOURCE - Winter 2016

First Person
APGA Events
Industry Update: Furnace Rule Report
The Future of Natural Gas in Zero Energy Building Design
Bringing Success to Succession in the Utility World
Taking a Fresh Look at Distributed Generation and CHP
Why Energy Codes Matter and How They Impact Your Utility
Environmental Group and Utility Work Together
Legislative Outlook
The Pipeline
Marketing Matters
At Last
Advertisers’ Index/
THE SOURCE - Winter 2016 - bellyband1
THE SOURCE - Winter 2016 - bellyband2
THE SOURCE - Winter 2016 - cover1
THE SOURCE - Winter 2016 - cover2
THE SOURCE - Winter 2016 - 3
THE SOURCE - Winter 2016 - 4
THE SOURCE - Winter 2016 - 5
THE SOURCE - Winter 2016 - 6
THE SOURCE - Winter 2016 - First Person
THE SOURCE - Winter 2016 - APGA Events
THE SOURCE - Winter 2016 - 9
THE SOURCE - Winter 2016 - Industry Update: Furnace Rule Report
THE SOURCE - Winter 2016 - The Future of Natural Gas in Zero Energy Building Design
THE SOURCE - Winter 2016 - 12
THE SOURCE - Winter 2016 - 13
THE SOURCE - Winter 2016 - Bringing Success to Succession in the Utility World
THE SOURCE - Winter 2016 - 15
THE SOURCE - Winter 2016 - Taking a Fresh Look at Distributed Generation and CHP
THE SOURCE - Winter 2016 - 17
THE SOURCE - Winter 2016 - 18
THE SOURCE - Winter 2016 - 19
THE SOURCE - Winter 2016 - Why Energy Codes Matter and How They Impact Your Utility
THE SOURCE - Winter 2016 - 21
THE SOURCE - Winter 2016 - Environmental Group and Utility Work Together
THE SOURCE - Winter 2016 - 23
THE SOURCE - Winter 2016 - Legislative Outlook
THE SOURCE - Winter 2016 - 25
THE SOURCE - Winter 2016 - The Pipeline
THE SOURCE - Winter 2016 - Marketing Matters
THE SOURCE - Winter 2016 - 28
THE SOURCE - Winter 2016 - 29
THE SOURCE - Winter 2016 - 30
THE SOURCE - Winter 2016 - Advertisers’ Index/
THE SOURCE - Winter 2016 - cover4
THE SOURCE - Winter 2016 - outsert1
THE SOURCE - Winter 2016 - outsert2
THE SOURCE - Winter 2016 - outsert3
THE SOURCE - Winter 2016 - outsert4