We continue to get questions regarding the record keeping requirements and how to prepare for the changes happening via the OQ NPRM. Here is a brief rundown of what to expect and how to be ready when the Final Rule rolls into effect (possibly later this year).
So what does the OQ NPRM have to say about record keeping?
§ 192.809 Recordkeeping.
Each operator must maintain records that demonstrate compliance with this subpart.
(a) Individual qualification records. Individual qualification records must include:
(1) Identification of qualified individual(s),
(2) Identification of the covered tasks the individual is qualified to perform;
(3) Date(s) of current qualification;
(4) Qualification method(s);
(5) Evaluation to recognize and react to an abnormal operating condition, whether it is task-specific non-task specific, which occurs anywhere on the system;
(6) Name of evaluator and date of evaluation; and
(7) Training required to support an individual’s qualification or requalification.
(b) Program records. Program records must include, at a minimum, the following:
(1) Program effectiveness reviews;
(2) Program changes;
(3) List of program abnormal operating conditions;
(4) Program management of change notifications;
(5) Covered task list to include all task specific and non-task specific covered tasks;
(6) Span of control ratios for each covered task:
(7) Reevaluation intervals for each covered task;
(8) Evaluations method(s) for each covered task; and
(9) Criteria and training for evaluators.
(c) Retention period— (1) Individual qualification records. An operator must maintain records of qualified individuals who performed covered tasks. Records supporting an individual’s current qualification must be retained while the individual is performing the covered task. Records of prior qualification and records of individuals no longer performing covered tasks must be retained for a period of five years.
(2) Program records. An operator must maintain records required by paragraph
(b) of this section for a period of five years.
■ 23. Section 192.1003 is revised to read as follows:
§ 192.1003 What do the regulations in this subpart cover?
(a) General. Unless excepted in paragraph
(b) of this section this subpart prescribes minimum requirements for an IM program for any gas distribution pipeline covered under this part, including liquefied petroleum gas systems. A gas distribution operator, other than a master meter operator or a small LPG operator, must follow the requirements in §§ 192.1005 through 192.1013 of this subpart. A master meter operator or small LPG operator of a gas distribution pipeline must follow the requirements in § 192.1015 of this subpart.
(b) Exceptions. This subpart does not apply to a service line that originates directly from a transmission, gathering, or production pipeline.
Wow, that is a lot of words, what does the OQ NPRM REALLY say about record keeping?
It is very technical and you can easily get lost without proper guidance (maybe reach out to EWN for a clearer picture). Basically, the big takes from this particular section regarding record keeping is as follows:
Individual Qualification Records, as outlined in the OQ NPRM – include those records for task identification, training required to support qualifications, qualification methods, the name of the evaluator & date of the evaluation. Items 1-4 (above) are currently included in the existing OQ Rule; 5-7 are new proposed requirements (above).
Program Records, as outlined in the OQ NPRM, include minimum standards for records for program effectiveness reviews, program changes, management of change notifications, and selection criteria and training for evaluators, etc. All these new & program requirement clarifications are listed in 192.809(b) and 196.509(b).
The bottom-line: What all of these things are essentially saying is PHMSA will be increasing its requirements to in-turn increase ‘tracking & traceability’. While the term is typically associated with integrity management issues, it applies to the OQ program requirements as a whole. PHSMA has been clearly supported API RP 1173 for Pipeline Safety Management Systems, the proposed Program Effectiveness Review requirements and the expanded Recordkeeping requirements reviewed here are a clear demonstration of PHMSA’s expectations that all companies have programs in place to guarantee safety & program compliance as a whole. The company should be able to identify gaps and weaknesses in their program, processes and document, measure progress and improve their programs efficiently.
How do I prepare for the additional recordkeeping changes in the OQ NPRM?
Simple, get started now. If you are not building your plan – you are already behind. This is just one of many changes coming down the pike that you MUST not sleep on. If you need help, better explanation or the tools necessary to track these records – call a professional: EWN (the trusted leader in compliance management and workforce development).