On January 28, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued revised Operator Qualification (OQ) FAQs. This new version will fully replace the existing FAQs.
APGA, along with the other industry trade associations, submitted comments on PHMSA’s proposed revisions in February 2021. In those comments, APGA emphasized the criticality of ensuring that the FAQs did imply requirements beyond those in the current pipeline safety regulations. Other key items raised in those comments were: differentiating between training and qualification; incorporating operations and maintenance (O&M) activities into OQ programs; differentiating between procedures and covered tasks; the use of the terms “characteristics, procedures, and equipment” when determining when OQ tasks should be updated; incorporation of emergency response tasks in OQ programs; and the proposed introduction of PHMSA’s Operator Qualification Glossary. Unfortunately, very few of industry’s comments were addressed.
However, in a note announcing the publishing of the new FAQs, PHMSA reminds operators that “Like all PHMSA guidance, FAQs are not rules, nor do they create legally enforceable rights, assign duties, or impose new obligations that are not contained in the existing regulations and standards. Pipeline operators must comply with the underlying safety standards referred to in the FAQs. “
View the new FAQs
here.
View the 2021 Comments
here.
For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-464-2742 or by email at
ekurilla@apga.org.