In 2013, The U.S Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed more than $9.7 million in civil penalties against pipeline operators who violate safety regulations. The figure is the highest yearly amount of proposed penalties in the agency’s history. PHMSA initiated 266 enforcement cases against pipeline operators for problems involving their integrity management programs, risk assessments, failure prevention and mitigation programs, and several other possible regulatory violations identified during failure investigations and routine inspections. Tougher enforcement is a result of PHMSA’s internal improvements to its pipeline inspection and tracking procedures.
As enforcement tightens around all aspects of pipeline safety, a critical piece to operator compliance is a comprehensive Operator Qualification (OQ) program. PHMSA strongly enforces its OQ regulations and has developed enforcement guidelines and strategies. Thus, it is vital for operators to understand and be totally conversant on these rules and guidelines. OQ is essential to overall pipeline safety performance and is critical in preventing system failures, injuries, property damage, and other serious consequences.
OQ is not intended to be a one-time event, but a continual process. All pipeline operators subject to Parts 192 and 195 are covered by the OQ rule and are responsible for ensuring that any employees, contractor employees and subcontractor employees who perform covered tasks on their pipeline systems are qualified in accordance with the rule. Operators must develop and maintain a fully qualified, compliant workforce. This one day course will provide guidance on all components of OQ regulations. PHMSA enforcement trends will be discussed. Attendees will leave the course with knowledge of the internal and external audit process and an interactive training session will be used to review the learning outcomes of this course. The instructor is a pipeline industry professional who has deep expertise in the requirements and day-to-day working experience with best-in-class programs.
Note: This course does not provide OQ certification for covered tasks. It is intended as a legal/regulatory compliance overview for attorneys, compliance managers and OQ program managers.
- Differentiate between federal regulations, state requirements, and the ASME B31Q task list for Operator Qualification (OQ) programs
- Review increasing scope of covered tasks
- Discuss intricacies and best practices of compliance documentation
- Discuss the recent PHMSA enforcement trends for OQ programs
- Demonstrate how to best prepare for OQ and operations and maintenance audit
EUCI has been accredited as an Authorized Provider by the International Association for Continuing Education and Training (IACET). In obtaining this accreditation, EUCI has demonstrated that it complies with the ANSI/IACET Standard which is recognized internationally as a standard of good practice. As a result of their Authorized Provider status, EUCI is authorized to offer IACET CEUs for its programs that qualify under the ANSI/IACET Standard.
EUCI is authorized by IACET to offer 0.8 CEUs for this event.
Requirements for Successful Completion of Program
Participants must sign in/out each day and be in attendance for the entirety of the course.
Case studies, PowerPoint presentations and classroom exercises will be used in the instruction of this course.
Monday, April 9, 2018
8:00 – 8:30 a.m. :: Registration and Continental Breakfast
8:30 a.m. – 5:00 p.m. :: Course Timing
12:00 – 1:15 p.m. :: Group Luncheon
Operator Qualification – Background and Overview
- Qualification standards before the OQ rules went into effect
- Development and promulgation of the OQ rules
- Overview of the federal regulatory requirements
- ASME B31Q Task List
- Developments in state OQ requirements
The Details: Guidance on the Requirements
- Employee OQ
- Contractor qualification
- Span of control
- Identifying covered tasks
- Documents and procedures
- Abnormal operating conditions and emergencies
- Maintenance vs new construction
- Re-evaluation intervals
Changes Coming for OQ: Proposed Rulemaking & Legislative Changes
Internal and External Audits
- Preparing for an audit
- Scope of OQ agency audits
- Recent audit results
What OQ Training Changes are Needed
OQ Interactive Training and Review
Charlene B. Wright, Managing Member, Wright & Associates PLLC
Ms. Wright advises clients on complex federal and state laws, agency regulations and industry standards including the Pipeline Safety Act, Federal Hazardous Materials Transportation law, Occupational Safety and Health Act, (OSHA) Toxic Substances Control Act, (TSCA), the PCB Mega Rule, LP Gas Code and NFPA Standards.
She represents clients in compliance, enforcement and permitting matters include those under the authority of the U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA), Federal Energy Regulatory Commission (FERC), Bureau of Ocean Energy Management Regulation & Enforcement (BOEMRE), U.S. Environmental Protection Agency (EPA), Federal Motor Carrier Safety Administration (FMSCA), United States Coast Guard, (USCG), State and Local LP Gas Agencies, the Texas Railroad Commission, and Transport Canada. Her experience includes drafting comments to proposed rules impacting the industry and analysis of legislative initiatives.
Ms. Wright defends energy clients in litigation resulting from rupture, leak, fire and explosion in state and federal courts. She has handled litigation in California, Colorado, Illinois, Kansas, Michigan, Minnesota, Missouri, New Mexico, New Jersey, New York, North Carolina, Ohio, Oklahoma, Oregon, Utah, and Wisconsin.
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