Once again this month, we will evaluate a task with the 4-part test as required by the Operator Qualification Rule. As we have discussed in previous issues, it is not always an easy decision when deciding whether or not a task is covered.
Is placing and maintaining line markers a covered task?
- Is it performed on a pipeline facility? The definition of a pipeline facility includes the pipeline right-of-way. Since these markers are placed in the right-of-way, this task is indeed performed on a pipeline facility.
- Is it an Operations and Maintenance task? This task is required under Subpart F of 49 CFR Part 195 Operations and Maintenance.
- Is it performed as a requirement of 49 CFR Part 192 or 195? This task is performed to comply with 49 CFR Part 195.410 (a) & (c)
- Does it affect the operation or integrity of the pipeline? Although the actual placement and maintenance of the markers themselves does not affect the operation or integrity of the pipeline, without the markers the pipeline integrity of the pipeline is in danger from third parties.
What do you think about these questions? Please email your comments on this or other tasks that you would like to have included in future newsletters to tdhollowell@your-rcp.com