Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators regarding interpretations and pending regulatory deadlines.
Q: Does any portion of a 192.635 “Notification of Potential Rupture” require OQ training as a covered task?
A: Yes, 192.635 “Notification of Potential Rupture” implicitly requires that employes and contractors who work along the ROW (or who remotely monitor pipelines) are able to identify potential ruptures and know how to respond. This competency should be incorporated into the operator’s Operator Qualification (OQ) program, as well as into Control Room Management (CRM) training.
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Upcoming Deadlines:
- The deadline to submit written comments in response to PHMSA’s forthcoming NPRM on Pipeline Safety: Safety of Gas Distribution Pipeline and Other Pipeline Safety Initiatives will be 60 days from the date of publication in the Federal Register. Comments may be filed at https://www.regulations.gov/ Docket No. PHMSA-2021-0046.
- And as a reminder, the “Stay of Enforcement” does not mean regulators don’t expect work toward getting compliance activities in place can be ignored.
If we can help, contact Jessica Foley.