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UNDERSTANDING DOT/PAM OPERATOR QUALIFICATION PROGRAM

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January 12, 2002

After a decade of deliberation between government and the pipeline industry, the action of the Notice of Proposed Rulemaking requiring qualification for individuals performing covered tasks on a pipeline facility is a reality. The synergistic efforts of the members of the Regulation Negotiation Committee resulted in the authoring of an acceptable proposed rule, Qualification of Pipeline Personnel. New Subparts to 192 and 195 are requiring pipeline operators to write a qualification program which identifies covered tasks, establishes evaluation methods, execute the evaluations to qualify individuals, preserve individual qualification, and maintain records of these activities. The written program must incorporate all the above requirements to accomplish the rule’s intent of ensuring a qualified pipeline work force to curtail incident probability and consequences caused by human error. The Regulators have the responsibility, hence the authority, to review Qualification of Pipeline Personnel programs, ensure that federal regulatory standards are complied with nationwide and may question an operator’s inclusion and/or exclusion of particular covered tasks. Program modifications may be required if it fails to meet rule requirements. The compliance time line is dependent on the Qualification of Pipeline Personnel Rule being published in the Federal Register which was August 27, 1999. The official compliance clock began when the rule was published in the Federal register. The operator must complete the written program by April 27, 2001 and must qualify all individuals performing on the pipeline facility by October 28, 2002. The primary advantage for the operator is that the operator writes a qualification program specific to his pipeline operating, maintenance and emergency response policies, procedures and practices. The impact on the operator will vary depending on what preparation the operator has accomplish to date. Those companies that waited for the final rule to be published in the Federal Register, may fine themselves rushing to complete the minimum requirements before the deadlines. The indisputable impact of the operators’ qualification program effectiveness will be manifested after Regulators critique the program or when a reportable incident is investigated

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