Introduction to Operator Qualifications

February 27, 2023 | Online

An Operator Qualification (OQ) program evaluates individuals that perform specific tasks during the operation and maintenance of a pipeline system and is required by the PHMSA for operators of natural gas and/or petroleum pipelines. Through these evaluations the company can assure that those performing those tasks are qualified and can do so in a safe and valid manner.

This intensive one-day course will go into detail on each of the key elements of an OQ program and explain the intent of each element while providing examples of how a company might comply with each of the specific regulatory requirements.

By registering today you will gain the information needed to have a valid program that addresses the wide array of operational and maintenance tasks performed on a pipeline system necessary to operate safely and comply with both Federal and State pipeline safety regulations.

Learning Outcomes 

• Describe the primary elements of an Operator Qualification program
• Discuss the 4-part test used to identify covered tasks and understand what qualifies as covered tasks
• Determine which individuals must be qualified
• Review evaluation (testing) methods used to qualify individuals
• How to prepare for audits (internal/external) and identify risks
• Review record keeping & documentation

MONDAY, FEBRUARY 27, 2023

Introduction

• Welcome and introduction
• Class agenda and objectives

Description of A Typical Operator Qualification Program

• Manual/procedures
• Process
• Applicability

Cover the 4-Part Test to Identify Covered Tasks

Determine Who is Subject to the Requirements of the Regulation

• Company personnel
• Contractor personnel

Methods That May Be Used to Evaluate Individuals

• Written-oral exam
• Work performance history review
• Actual performance of task
• Simulation

Evaluation Process

• Who can be an evaluator
• In-house vs. contract evaluators
• Steps in the evaluation process
• Documentation

Span of Control

• Qualified vs. non-qualified individuals
• Applicable to which covered tasks

Preparing for Internal and/or External Audits

• Identify risks

Record Keeping

Summary & Comments

Pipeline Safety Regulations

February 28, 2023 | Online

The pipeline industry is under heightened scrutiny by regulators, the media, and the public. The NTSB highlighted aging pipelines as a concern in its 2019-2020 Most Wanted List of Transportation Safety Improvements. Likewise, Congress has ongoing interest in the safety of older transmission pipelines and in the replacement of leaky and deteriorating cast iron pipe in natural gas distribution systems. 

The Pipeline Safety Regulations course will highlight changes in the law and explain how companies can address compliance challenges in the context of stricter regulator interpretations of current regulatory requirements and increased enforcement. The course will dive into developing an increased awareness of the scope and content of regulations and how to best comply with those rules.

Learning Outcomes

• Review pipeline regulations and LNG facilities in the U.S. and discuss PHMSA’s regulatory and enforcement processes   
• State the current perspective on heightened scrutiny regarding pipeline safety
• Delineate the statutory and jurisdictional framework for PSA for natural gas and hazardous liquids 
• Review the regulatory provisions in Parts 191, 192, 194, and 195 and Safety Management Systems (SMS) API RP 1173
• Discuss hazardous liquid, gas transmission, and gathering pipeline safety
• Dissect new regulations and developments and new understandings with underground natural gas storage, gas gathering, and LNG facilities
• Explain regulatory inspections and enforcement trends
• Describe Natural and Other Gas Pipeline Safety Regulations 49 CFR 192
• Review Hazardous Liquid Pipeline Safety Regulations 49 CFR 195
• Describe LNG Safety Regulations 49 CFR 193

TUESDAY, FEBRUARY 28, 2023

Course Overview

Historical Overview

• Enactment of legislation for federal pipeline safety program
• Subsequent legislation that reauthorized and amended the program
• Factors that led to the creation and evolution of pipeline safety laws and regulations

 Principles of Pipeline Safety Regulation

• Framework for the regulation of gas pipeline and hazardous liquid pipeline facilities
• Role of the federal government and states in regulating pipeline safety, federal preemption, non-retroactivity, rulemaking, and special permits (or waivers)
• Powers, authorities, and principles that guide federal and state pipeline safety programs

Gas Pipeline Safety Regulations

• Overview of the minimum federal safety standards for gas pipeline facilities in 49 C.F.R. Part 192
• Requirements that apply to regulated gathering, transmission, and distribution lines
• Significant rulemaking proceedings that could impact those requirements

Hazardous Liquid Pipeline Safety Regulations

• Minimum federal safety standards for hazardous liquid pipeline facilities in 49 C.F.R. Part 195
• Requirements that apply to regulated pipelines
• Rulemaking proceedings that could impact those requirements in the future.

Safety During COVID

Closing Remarks

Keith Coyle, Attorney, Babst Calland

Keith Coyle is a member of the Firm’s Washington, D.C. office and a shareholder in the Energy and Natural Resources, Environmental and Transportation Safety groups and Pipeline and HazMat Safety practice. Mr. Coyle advises clients throughout the United States on energy matters, but his practice focuses primarily on the regulation of pipelines and liquefied natural gas (LNG) facilities and the transportation of hazardous materials. He has significant experience working on these issues for clients in the private sector, as a former government attorney, and through his participation in industry task forces and trade organizations.

Varun Shekhar, Associate, Babst Calland

Varun Shekhar is a senior associate in Babst Calland’s Environmental and Transportation Safety groups. Mr. Shekhar’s Transportation Safety practice emphasizes pipeline safety matters arising under Pipeline and Hazardous Materials Safety Administration (PHMSA) regulations for both natural gas and hazardous liquid pipeline systems. Moreover, he regularly advises clients within a wide variety of industries on PHMSA’s hazardous materials regulations (HMR), as well as regulations administered by the Federal Railroad Administration (FRA) and the Federal Motor Carrier Safety Administration (FMCSA).