What is PHMSA Form 14?

PHMSA’s 9 OQ Inspection Protocols

As we mentioned in our last article, PHMSA’s 9 Inspection Protocols historically were listed 1-9 with each having several sub-parts. In August of 2013, PHMSA split the nine protocols into individual sub-elements. These are now listed numerically on PHMSA’s Form 14.

The purpose of Form 14 is to ensure that operators can demonstrate that their OQ programs address each protocol and describe how their program would be effective in their absence. In addition, all workers’ training and requalification progress and documentation will need to be maintained via a secure records management system. This week we will be discussing two of the elements that focus on how to handle contractor, sub-contractor and even mutual aid qualifications PHMSA Form 14 #’s 3 and 4.

PHMSA defines a covered task as an activity, identified by the operator, that: (1) is performed on a pipeline facility; (2) is an operations or maintenance task; (3) is performed as a requirement of this part, and (4) affects the operation or integrity of the pipeline.

#3. Contractors Adhering to OQ Plan

Does the process require the OQ plan to be communicated to contractors and ensure that contractors are following the plan? 192.805(b); 192.805(f); 192.805(c)

#4. Contractor and Other Entity Qualification

Does the process require contractor organizations or other entities that perform covered tasks on behalf of the operator to be qualified? 192.805(b); 192.805(c); 192.855(d); 192.805(e); 192.805(f)

Each operator shall have a written qualification program that they follow. The program shall include provisions to:

(a) Ensure thorough evaluation that individuals performing covered tasks are qualified.

• The operator is required to qualify the tasks using the company program or ensure that the other contracted parties are qualified in accordance with the regulations.

(b) Allow individuals that are not qualified pursuant to this subpart to perform a covered task if directed and observed by an individual that is qualified.

• Operators are permitted to allow tasks to be performed by non- qualified individuals as long as the individual is directly observed by qualified individuals within their span of control.
• Certain tasks cannot be performed by non-qualified individuals regardless of direct observation.

(c) Evaluate an individual if the operator has reason to believe that the individual’s performance of a covered task contributed to an accident or incident.

• Operators are required to conduct a review of individual performance following an incident or accident.

(d) Evaluate the individual if the operator has reason to believe that the individual is no longer qualified to perform a covered task.

• Operator’s written plans are required to include examples of typical reasons why an individual’s qualification(s) may be called into question or review.
• Examples include physical or mental impairment, time away from the job or task, or failure to perform the task correctly including reacting and responding to AOCs.
• Once removed from a job or task, consideration is also given to how long an individual will be removed from the job and provisions for returning to the task (i.e. through training and/or evaluation).

(e) Communicate changes that affect covered tasks to individuals performing those covered tasks.

• Each operator shall have a Management of Change provision to determine what circumstances result in the timely notification of the change and how the communication will be distributed to all affected parties. This includes contractors performing covered tasks as they may be different.

In summary, not only are Operators required to ensure the qualification of their workers, but also the workers of contractors and sub-contractors and even Mutual Aid personnel who perform tasks on their pipeline. Numbers 3 and 4 of PHMSA Form 14 address communicating effectively with contractors and other entities who perform tasks on an Operator’s pipeline. These guidelines include how to evaluate individuals, communicate changes, and confirm the qualification status of contractor or sub-contractor employees. For more information on the PHMSA Protocols visit their website at Phmsa.dot.gov.

Stay tuned for next week when we cover Element #6 and Element #7, and discuss why #5 is not included on Form 14.