The
Department of Transportation/Pipeline Hazardous Materials Safety Administration
(PHMSA) issued Advisory Bulletin ADB-09-03 informing pipeline operators about
the standardized notification process for operator qualification (OQ) plan
transmittal from the operator to PHMSA. PHMSA has added to the glossary of
definitions of the terms “Observation of on-the-job performance” as
applicable to determining employee qualification and “Significant” as
applicable to OQ program modifications requiring notification. The Advisory
also makes other miscellaneous clarifications regarding OQ programs.
Standardized Plan Transmittal Process
Operators should send notifications of significant modification of an OQ
Program to the OPS Information Resource Manager by e-mail at InformationResourcesManager@phmsa.dot.gov or mail to:
U.S. Dept. of Transportation, PHMSA
Office of Pipeline Safety, Information Resources Manager
1200 New Jersey Avenue, SE.
East Building, 2nd Floor (PHP-10), Room E22-321
Washington, DC 20590.
Note: Operators subject to regulation by State agencies are required to send OQ
notifications directly to each State agency. Regardless of the delivery method,
each notification to PHMSA should include:
- OPID(s), operator name(s), HQ address. Name of individual submitting notification, Data/email/phone number, Commodity (gas/liquid/both), PHMSA Region(s) where pipeline(s) operate, and names of respective facilities or pipeline systems where changes apply.
- Complete Plan accompanied by revision/change log and effective date of change(s). The plan should be notated such that changed areas of the plan can be readily identified. Employee-specific information (i.e., social security numbers) and testing material are not needed.
Definitions
With respect to the use of “Observation of on-the-job performance” as
a means of determining employee qualification, PHMSA has added a definition of
this term to its glossary of terms on the PHMSA Primis OQ Web site. PHMSA also
added a definition of the word “significant” to the glossary as it
applies to modifications to an operator’s OQ program. The definitions read as
follows:
- Observation of On-The-Job Performance
- Observation without interaction during on-the-job performance does not provide an adequate measurement of the knowledge and skills of the individual;
- PHMSA has determined that there are no covered tasks to date where observation of on-the-job performance is an adequate, sole method for examining or testing qualification; and
- Observation of on-the-job performance does not measure the individual’s ability to recognize and react to abnormal operation conditions (AOCs).
- Significant
As applicable to OQ program modifications, significant includes but is not limited to: increasing evaluation intervals, increasing span of control ratios, eliminating covered tasks, mergers and/or acquisition changes, evaluation method changes such as written vs. observation, and wholesale changes made to OQ plan.
Miscellaneous Clarifications
To clarify the requirements of 49 CFR 192.605(a) and 195.402(a) as they apply
to OQ and written OQ program reviews, the following information is provided:
- The OQ process and procedures are an important part of an
operator’s manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies
(O&M Plan).
- Operators’ review of their OQ Plan in accordance with § 192.605(a) and 195.402(a) should be conducted in connection with their reviews of their O&M Plans every 15 months, but at least once each calendar year.
- Operators’ “periodic review of work” being done in
accordance with § 192.605(b)(8) and 195.402(c)(13), should include evaluation
of OQ procedure effectiveness to identify where corrective actions are needed
to address deficiencies. Examples of issues that need to be reviewed to
determine the effectiveness of an OQ Program:
- Adequacy of training for specific covered task(s),
- Adequacy of evaluation(s) to determine if individual has required knowledge, skills, and abilities,
- Adequacy of individual to recognize AOC(s), and
- Adequacy of individual to take appropriate action after AOC.
- Operators should ensure the record it maintains of its annual O&M review, as required by § 192.605(a) and 195.402(a), specifically notes that the OQ Plan was included in the review. The record should include the name of reviewer and date(s) of review. Alternatively, the operator’s review procedures may clearly indicate which procedures are to be evaluated during the annual review.
- PHMSA will inspect annual review records to assure OQ Plans are being evaluated and may take compliance action where non-compliance is found.