DOT Pipeline Compliance News

March 2010 Issue

In This Issue

PHMSA Casing Workshop (April 28, 2010) Location: Baltimore

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) is conducting a “Casing Workshop Part 2 – Draft Guidelines for Integrity Assessment of Cased Pipe in Gas Transmission Pipelines.” The workshop is intended to discuss the draft PHMSA guidance “Guidelines for Integrity Assessment of cased Pipe” and related FAQs prior to finalizing the guidance material. The latest guidelines and FAQs are available on the PHMSA GasIMP “Main Documents” page. There is no charge to attend, and the workshop will not be webcast. Click here for more information and registration.

Modifications to Drug and Alcohol Data Collection Forms

[Docket DOT-OST-2008-0088]

The Department of Transportation (DOT) has made technical amendments to its drug and alcohol testing procedures to authorize employers to begin using the updated U.S. DOT Alcohol Testing Form (ATF) and the Management Information System (MIS) Data Collection Form. The ATF and MIS were updated to include an updated Paperwork Reduction Act Burden Statement, the current address of the Department, and new DOT form numbers. Additional instructions on the reverse side of Page 3 of the ATF require that tamper evident tape must not obscure the printed information. Also, the legends in the test result boxes on the front of the ATF were adjusted and printed in a smaller font so they don’t obscure test results printed directly on the ATF. Other than these changes, the content and format of ATF from the previous versions remain the same.

The Department recognizes that employers and alcohol testing technicians may currently have a large supply of old ATFs. To avoid unnecessarily wasting these forms, the Department will permit the use of the old ATF until supplies are exhausted, but the old ATF must not be used beyond August 1, 2010. Employers are authorized to begin using the updated ATF immediately.

For further information contact: Bohdan Baczara, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue, SE., Washington, DC 20590; (202) 366-3784 (voice), (202) 366-3897 (fax), or email

RCP’s Web-Based Compliance Management Systems

CP’s Compliance Management System (CMS) is an invaluable tool for managing all aspects of regulatory workflow. Some examples of how our clients are using the CMS include:

  • O&M Scheduling and Data Acquisition;
  • Cathodic Protection Inspection and Data Management;
  • One-Call Screening and Ticket Management;
  • Repair / Replacement Programs;
  • Operator Qualification Administration and Workflow Integration;
  • Leak Life Cycle Management;
  • Environmental, Health and Safety Compliance;
  • Audit Action Item Tracking; and
  • Customer Data Management.

DIMP Integration

For gas distribution operators looking for a powerful tool to implement DIMP, the RCP CMS integrates O&M data captured from field personnel along with inherent system attributes to provide real-time risk analysis, performance reporting, as well as track additional and accelerated actions taken to mitigate risks.

Key Features

  • GIS integrated workflow management
  • Custom tailored e-mail notifications and reporting
  • Runs on any web-enabled device, no software to download
  • Powerful reporting and custom query functionality
  • Multiple security and user privilege settings
  • Document storage and control (ex. procedures, maps, images, and completion documentation)
  • Automatic recurrence setting for routine tasks (example: leak surveys, CP surveys, etc.)
  • Create work orders for unscheduled / unplanned activities (ex. release reporting)

To request a demonstration or to request more information, please contact Jessica Roger.

Notice of Minimum Annual Percentage Rate for Random Drug Testing

[Docket ID PHMSA-2010-0034]

Operators of gas, hazardous liquid, and carbon dioxide pipelines and operators of liquefied natural gas facilities must select and test a percentage of covered employees for random drug testing. Pursuant to 49 CFR 199.105(c)(2), (3), and (4), the PHMSA Administrator’s decision on whether to change the minimum annual random drug testing rate is based on the reported random drug test positive rate for the pipeline industry. The data considered by the Administrator comes from operators’ annual submissions of Management Information System (MIS) reports required by 49 CFR 199.119(a). If the reported random drug test positive rate is less than one percent, the Administrator may continue the minimum random drug testing rate at 25 percent. In 2008, the random drug test positive rate was less than one percent. Therefore, the minimum random drug testing rate will remain at 25 percent for calendar year 2010.

For further information contact: Stanley Kastanas, Program Manager, Substance Abuse Prevention Program, PHMSA, U.S. Department of Transportation, telephone 202-550-0629 or e-mail

Reporting of Drug and Alcohol Results for Contractors and Multiple Operator IDs: ADB.09.04

[Docket ID PHMSA-2010-0034]

On January 19, 2010, PHMSA published an Advisory Bulletin (75 FR 2926) implementing the annual collection of contractor MIS drug and alcohol testing data. All applicable Sec. 199.119 (drug testing) and Sec. 199.229 (alcohol testing) MIS reporting operators must now submit all contractor MIS reports to PHMSA, as well as their own, by March 15, 2010. Contractors with employees in safety-sensitive positions who performed, as defined in Sec. 199.3 of 49 CFR Part 199, covered functions (i.e., maintenance, operations or emergency-response), must submit these reports through the auspices of each operator for whom these covered employees performed those covered functions. While the applicable regulations have always required operators to track contractor drug and alcohol results, PHMSA had not previously required the operators to submit that data to PHMSA.

The advisory bulletin also contains guidance on the submittal of drug and alcohol results by operators who have multiple operator identification numbers.

SPCC Plan Workshop May 19, 2010 / Houston, TX

Join us May 19, 2010 in Houston at the Crowne Plaza Downtown for an informative and interactive workshop on SPCC Plan Preparation. The workshop will cover the regulation and requirements of an SPCC Plan in depth and its impact on a facility. It will also provide all the information necessary to properly develop or modify an SPCC Plan in full compliance with the latest amendments and revisions. At the conclusion, participants will have a thorough understanding of the rule requirements, and should be able to update or write and certify their own plan (if self-certification is an option). This workshop is appropriate for people who are responsible for SPCC Plan preparation, for those seeking to update or modify their plans, or anyone who needs to know the latest information on the rule changes.


  1. SPCC Overview / History
  2. The regulation and the November amendments
  3. The requirements of an SPCC Plan in depth
  4. A discussion of the impact of the SPCC Plan on your facility
  5. Inspections, training and Plan updates

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

RCP in Industry Publications

You know those pipeline and gas journals that pile up on the corner of your desk? Take a few moments to look for these recent articles from Bill Byrd, President of RCP.

  • New Control Room Management Regulations Require Structured Management Approach, p. 32, in the February 2010 issue of the Pipeline and Gas Journal.
  • SPCC Rule Revisions Affect Gas Processing Facilities Feature article of the February 25, 2010 Vol. 28 Issue 8 of the Gas Processors Report (GPA Newsletter publication)
  • The New SPCC Rule: Are You in or Out?, p.6 in the February 19, 2010 Vol. 13, No. 4 Issue of The TIPRO Target (Texas Independent Producers & Royalty Owners Association Newsletter publication)

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.

Pirate Digs 811

The Common Ground Alliance (CGA) has created an educational video for children ages 8 to 11 years on the importance of calling 811 before you dig. The video is 7 minutes long and teaches children about damage prevention and its relevance to their everyday lives. The videos can be purchased by individuals or companies for $61.50 (per box of 50). To see a preview clip of the video, click here. Know Whats BelowCall Before You Dig!

For more information, or to order your copies, contact the CGA at:

RCP News – Weather

Related events? In what resulted in the largest television audience in history, the perpetual losers of the NFL, the New Orleans Saints, overcame a 10 point deficit to beat the Indianapolis Colts by 2 touchdowns in the 2010 Superbowl. In related news, Washington DC froze over in a massive snowstorm. Its proximity to hell may have been a contributing factor.

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