Regulatory Submissions

APGA Comments on Proposed Operator Qualification and Incident Notification Rules 

09-02-2015 05:24 PM

On September 1, APGA filed written comments with the Pipeline and Hazardous Materials Safety Administration (PHMSA) on changes to operator qualification and incident notification regulations. PHMSA proposed to require operators to report incidents within one hour after the “confirmed discovery” that a reportable incident has occurred. A reportable incident is a release of gas that results in death, injury requiring hospitalization, property loss exceeding $50,000 or the loss of more than one million cubic feet of gas. PHMSA also proposed to require operators to follow up the initial notice within 48 hours to update information provided in the initial notice. Both of these changes were mandated by the 2011 reauthorization of the Pipeline Safety Act. APGA objected to PHMSA’s proposal that the operator provide estimated quantity of gas lost in the initial notification. Operators are unlikely to have this information until after the incident is brought under control. The law did not require this quantity released until the 48-hour update. PHMSA proposed substantial changes to the operator qualification (OQ) rules. PHMSA proposed to change the definition of “covered task” to include construction and emergency response tasks. It added criteria for what must be evaluated for an individual to be considered qualified. It added requirements that each operator annually assess the effectiveness of its OQ program, develop a management of change procedure, and define criteria for evaluators. PHMSA also added requirements for recordkeeping including records of training. APGA’s comments objected to recordkeeping provisions that could be interpreted to require the operator to provide training to employees who are already qualified to perform a task. APGA’s comments urged PHMSA to limit training records to only those employees who need training, such as new hires, employees performing tasks they had not previously been qualified for, or for employees who have had qualification revoked for cause. APGA made other suggestions to reduce the burden the rule changes would place on operators. A copy of APGA’s comments are attached. For questions on this article, please contact John Erickson of APGA staff by phone at 202-464-0834 or by email at jerickson@apga.org.

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APGA comment on PHMSA OQ-Notification NOPR of 7-10-15.pdf   308 KB   1 version
Uploaded - 09-02-2015

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