We all knew when PHMSA first started organizing the next OQ NPRM that change was coming. Our industry has gone through this already once before back in 2011-2012, so we knew we would have time to get organized and fully understand the impacts of the OQ NPRM. The time to comment has passed (only 35 entities commented in total, not a lot), and it looks more and more like we will see the Final Rule in place sometime in October (or by end of the year).
What do the changes mean to me?
That means that you need to be ready for the changes that impact your company. If you are not prepared to manage your OQ records properly, you are not managing change correctly, you do not fully understand the span of control changes, you are not ensuring your program effectiveness and are not ready to notify your staff when changes are being made – you are going to be behind from the get-go.
How do I prepare for the OQ NPRM changes?
Easy – call EWN. EWN is the trusted leader in compliance management, workforce development, and OQ. It isn’t going to be an easy task, there are no shortcuts – but EWN has the staff to prepare you, the tools to ensure you are taken care of and the experience to help you feel secure.
How long will I have to implement these changes?
Based on prior OQ NPRM changes, we estimate that the implementation period will be 12-18 months (we are leaning more towards 12). This might seem like a lot of time, but in reality – if you haven’t started already, it is going to fly by. Ensuring your OQ strategies are up to snuff is going to take time – educating your staff and implementing & documenting your processes. This implementation time will go quickly, and with an increased amount of auditors – you can expect the penalties to show up soon thereafter.
Who can help my company with these changes?
EWN. Call them – they can help immediately. 855.396.5267
What is the OQ NPRM and what does it come from?
The Pipeline and Hazardous Materials Safety Administration (PHMSA) has proposed amendments, updates and clarifications to the pipeline safety regulations to address Section 9 (Accident and Incident Notification) and Section 13 (Cost Recovery for Design Reviews) of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (2011 Act), and to certain other regulatory requirements. PHMSA has also proposed changes to the Operator Qualification (OQ) requirements and drug and alcohol testing requirements and incorporating consensus standards by reference for in-line inspection (ILI) and Stress Corrosion Cracking Direct Assessment (SCCDA) in Part 195.
The public comment period for these proposed changes ended on September 8, 2015. PHMSA received comments from 35 entities. On June 1, 2016, the Gas Pipeline Advisory Committee (GPAC) and the Liquid Pipeline Advisory Committee (LPAC) met in Arlington, VA., to review several the regulations proposed by PHMSA. The GPAC and LPAC are congressionally-mandated peer review committees composed of industry, government and public pipeline safety experts that advise whether PHMSA’s proposed rules are reasonable, practical, technically feasible and cost-effective.