DOT Pipeline Compliance News

January 2010 Issue

In This Issue

Extension of Comment Period – DIMP Coupling Failure Reporting Requirement

[Docket No. PHMSA-RSPA-2004-19854]

On December 4, 2009, PHMSA published a final rule (74 FR 63905) under Docket No. PHMSA-RSPA-2004-19854 amending the Pipeline Safety Regulations (49 CFR Parts 190-199) to require operators of gas distribution pipelines to develop and implement integrity management programs. In that final rule, PHMSA adopted a requirement that operators report failures of all compression couplings, both plastic and metallic. PHMSA also invited public comment on the requirement to report failure of compression couplings used in metal pipe. Public comments were due by January 4, 2010.

The American Gas Association (AGA) requested that PHMSA extend the comment period for thirty days so that gas utilities have the opportunity to thoroughly review the regulation and draft annual report. AGA went on to say that extending the comment period is the only way to provide PHMSA with the necessary information to establish clear and consistent data. PHMSA agrees that additional time should be allowed and is extending the comment period from January 4, 2010 to February 4, 2010.

Submit comments to Comments should be limited to the provisions on reporting failures of mechanical couplings, and should reference Docket No. PHMSA-RSPA-2004-19854.

DOT Pipeline Compliance Workshop – Gas, Liquids, DIMP & Control Room Management

March 2, 3, and 4, 2010 / Houston, TX

Join us March 2-4, 2010 in Houston at the Crowne Plaza Downtown for an informative, lively, and interactive workshop on DOT Pipeline Compliance and OPA Planning for DOT Pipelines. This workshop has been attended by hundreds of pipeline personnel, with excellent feedback. The workshop provides an overview of the DOT pipeline regulations, and is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest information in these areas.


Day 1 (March 2): Gas Pipeline Regulations (49CFR192)

Each attendee will receive general training materials which include the applicable DOT 49 CFR 192 regulations for gas pipelines (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts. The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations, roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification, public awareness; and a specific emphasis on the gas integrity management regulations.

Day 2 (March 3): DIMP and Control Room Management

Morning Session: DIMP
On December 4, 2009, PHMSA published the final rule for Distribution Integrity Management Programs (DIMP) which is applicable to gas distribution operators and becomes effective on February 2, 2010. The DIMP regulations are listed in Part 192 as a new Subpart P – Gas Distribution Pipeline Integrity Management. The compliance deadline for developing a written distribution IM plan and implementing the plan is August 2, 2011 (18 months from the effective date). This workshop session will discuss the written distribution IM plan and the required seven elements for existing gas distribution pipeline systems, five new key definitions, annual reporting, in addition to the other key requirements of this Final Rule.

Afternoon Session: Control Room Management
On December 3, 2009, PHMSA published their final rule on control room management for gas and liquid pipeline operators to amend their existing written O&M procedures, operator qualification (OQ) programs, and emergency plans to assure controllers and control room management practices and procedures used maintain pipeline safety and integrity. The Final Rule adds provisions to 49 CFR parts 192, 193, and 195. This workshop session will discuss the regulations that address fatigue management and other components of control room management, i.e. alarm management, controller qualifications, controller human factors, and management of change.

Day 3 (March 4): Liquid Pipeline Regulations (49CFR195)
Each attendee will receive general training materials which include the applicable DOT 49 CFR 195 regulations for hazardous liquid pipelines (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts. The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations, roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; spill response planning requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification and public awareness.

To register, or for additional information, go to our website.

Advisory Bulletin ADB-09-03 – Operator Qualification Programs

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 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.


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:

  1. 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).
    1. 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.
    1. 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:
      1. Adequacy of training for specific covered task(s),
      1. Adequacy of evaluation(s) to determine if individual has required knowledge, skills, and abilities,
      1. Adequacy of individual to recognize AOC(s), and
      1. Adequacy of individual to take appropriate action after AOC.
  2. 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.
  3. PHMSA will inspect annual review records to assure OQ Plans are being evaluated and may take compliance action where non-compliance is found.

Need to Update Your Current Operator Qualification Program?

We have the expertise to update your current operator qualification program to satisfy the upcoming regulation change and inspection protocols. Click Here to request more information.

Florida Pipeline Safety Regulations – Misc. Revisions and Updates

The state of Florida has modified their gas pipeline safety regulations (Division 25 – PSC, Chapter 12 – Safety of Gas Transportation by Pipeline) to incorporate more recent editions of standards and federal regulations, make various minor modifications to specific requirements in Florida, and to change reporting requirements.


Are you ready? Does your SPCC Plan include the latest amendments as published on November 13, 2009? If not, RCP can develop or modify your SPCC Plan. Contact us today for more information.

2010 ASME International Engineering Congress and Exhibition – Call for Abstracts

Our president, Bill Byrd, is chair of the Safety Engineering, Risk Analysis, and Reliability Methods track at the ASME International Engineering Congress and Exhibition in Vancouver, Canada, November 12 – 18, 2010. Authors are encouraged to submit abstracts for papers that they would like to present at the congress. In addition to the general topics of safety engineering, risk analysis, and reliability methods, a special topic is planned for Safety in Transportation. The deadline for abstract submittal is March 1, 2010. Additional information can be found at the congress website or by contacting Bill Byrd.

Are you ready for a Public Awareness Plan Audit?

A recent NTSB accident investigation determined that an operator’s oversight and evaluation of the effectiveness of the public education program, and the performance of the public awareness contractor, were inadequate. The NTSB recommended that PHMSA exercise their right to review the operators’ evaluation process to determine the effectiveness of the public awareness plans developed. Will your plan stand up to a PHMSA audit?

Also, if you wrote your Public Awareness Plan 5 years ago, you may be due for a review. RCP can assist you by reviewing your plan and conducting an effectiveness evaluation. Contact Jessica Roger for more information.

PHMSA Pipeline Construction Website

This may be old news for some, but PHMSA has posted a page on their website dedicated to pipeline construction. The site includes a list of Frequently Asked Questions, reference documents, a list of hot-button issues observed by PHMSA inspections over the last few years of pipeline construction growth, as well as a summary of the issues and presentations made during the April 2009 workshop on pipeline construction in Ft. Worth, TX. If you are interested in exploring this site, go to

API Pipeline Conference and Cybernetics Symposium April 19 – 22, 2010

The Annual API Pipeline Conference will be held April 19-22 at the Astor Crowne Plaza Hotel in New Orleans, LA. The premier conference and symposium of their kind in the U.S. will provide over 100 session topics of critical importance to the pipeline and related industries. Early registration ends March 31, 2010 and the cut off date for making hotel reservations is April 1, 2010. For a preliminary agenda and more information click here.

Bill Byrd signature
W. R. (Bill) Byrd, PE
RCP Inc.