In This Issue

PHMSA Advisory Bulletin: Guidance on Training and Qualifications for the Integrity Management Program (ADB-2017-02)

[Docket No. PHMSA-2016-0067]

PHMSA issued a new Advisory Bulletin (ADB-2017-02) for operators of natural gas transmission pipelines, outlining their expectations for qualifications of personnel who perform or supervise integrity management activities. PHMSA inspectors will use this Advisory Bulletin to clarify the intent of existing regulatory language when evaluating operator IM program personnel training and qualification effectiveness. Specifically, PHMSA advises that operators have the necessary qualifications and training for those personnel that:

  • Have a role in executing the integrity management program,
  • Have supervisory authority over integrity management activities, and
  • Carry out integrity assessments and evaluate assessment results.
  • Implement preventative and mitigative activities.

Qualification criteria must include minimum requirements for experience or training in order to verify individuals have the knowledge and skills necessary to perform integrity management-related tasks; and the operator must determine whether qualifications are current. Documentation of qualification must be maintained. The rule requires operators to verify that the personnel who execute activities within the integrity management program are qualified in accordance with the quality assurance process required by §192.911(l). Qualification requirements must be established for all tasks necessary to carry out integrity assessments and evaluate assessment results, including:

  • Performing the integrity assessment;
  • Evaluating the results of the integrity assessment;
  • Integrating any other available information or data gathered in accordance with §192.917(b) that is applicable to the covered segment being assessed; and
  • Deciding on actions to be taken based on these assessments.

For a copy of this Advisory Bulletin or to inquire how RCP can assist with these requirements, contact Jessica Foley.