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PHMSA Releases Updated Enforcement Guidance

The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) recently released updated enforcement guidance for complying with its operator qualification (OQ) and hazardous liquid integrity management program (IMP) requirements.  PHMSA’s OQ requirements establish minimum federal safety standards for the qualification of individuals who perform covered tasks.  A covered task is an activity identified by the operator that is performed on a pipeline facility, is an operations and maintenance task, is performed as a requirement of the pipeline safety regulations, and which affects the operation or integrity of the pipeline.  PHMSA’s IMP requirements apply to hazardous liquid and carbon dioxide pipelines that could affect a high consequence area (HCA) in the event of a leak or failure.  HCAs include commercially navigable waterways, certain populated areas, and other areas that are unusually sensitive to environmental damage.  PHMSA’s enforcement guidance provides information on each of the regulatory provisions, including a recitation of the applicable text, summaries of the relevant interpretations, advisory bulletins, and other reference materials, and examples of situations that might result in probable violations.