COOQ Makes Progress on Operator Qualification

The Consortium On Operator Qualification (COOQ), chaired by Mark Cline of Marathon-Ashland Petroleum, is a joint industry workgroup of 28+ liquid pipeline operating companies that have pooled their resources to address common implementation issues related to the new Operator Qualification rule. Their initial work, which has been incorporated into the pending API Publication #1161, resulted in a list of 45 "covered tasks" for liquid pipelines that meet the OQ rule 4-part test requirements. The COOQ is now expanding on that initial work by further defining each covered task to identify the subtasks (or elements) of each task. These subtasks will define a performance standard or specification for the covered task. For example, a covered task could be "inspect, test and calibrate relief valves". Subtasks could include: calibrating pressure indicators, pressurizing the valve, measuring relief pressures, adjusting relief set pressures, identifying equipment requiring repair and replacement, maintaining test documentation, and so on.

Eventually the COOQ hopes to develop a common framework of task performance "specifications" that can be incorporated into an industry standard qualification program. Contractors would demonstrate that their employees can perform these tasks to these specifications, possibly through some third party certification program (for quality control). This would allow contractors to use a common system and common set of performance standards that could be accepted by most pipeline operators. Of course, pipeline operators could choose to have their own employees qualified using these same methods.

The COOQ plans to publish their work products under the aspices of API, and is working with API to develop the necessary framework for contractor qualifications and third party certification programs. The COOQ is a working committee. If your company would like to contribute to this effort, please send an e-mail to Mark at MRCline@MAPLLC.com. Membership is limited to pipeline operating companies.

Russian Legislators Learn About Pipeline Safety

RCP's president was recently selected to give a presentation to a group of Russian legislators concerning U.S. regulation of pipeline safety. The Russian delegation was especially interested in the division of Federal / State responsibilities, enforcement of regulations, and in the rulemaking process versus the legislative process.

Pipeline Integrity Management in High Consequence Areas

The docket on this proposed rulemaking has been very active lately (comments were due by 6-23-2000). In addition to the typical commenting organizations, comments have also been received from Friends of the Aquifer, National Pipeline Reform Coalition, Fuel Safe Washington, The City of Bellingham, Environmental Defense, and the Pipeline Survivor's Association. You check out these and all other items on the docket by going to the DOT's Docket Management System at http://dms.dot.gov, and search for docket number 6355.

API Progress on Pipeline Integrity Management Standard

On June 23, 2000, API filed their comments on the proposed Pipeline Integrity Management rulemaking. In those comments, API made to following statements, which give a good summary of their work to date and plans concerning their planned Pipeline Integrity Management standard:

"We are pleased to report that the following progress has been made in developing the consensus integrity standard –

  • A work group has been created and has held three meetings. The work group includes pipeline operators, inspection technology vendors, inspection service companies, representatives from the American Society of Mechanical Engineers (ASME B31.4), representatives from the National Association of Corrosion Engineers, OPS inspectors, and OPS headquarters personnel.
  • The work group has encouraged broad participation, including issuing specific invitations to pipeline safety advocates, such as the participants in the recent national conference sponsored by the National Pipeline Reform Coalition, to participate in the development of and to comment on the integrity standard.
  • The work group issued a discussion draft of the standard for broad public review on May 25, 2000 and has asked that OPS post that discussion draft to the docket for this rulemaking. (Editor's note: the discussion draft is available on RCP's website at http://www.your-rcp.com/downloads/Misc/API Discussion Outline 5-25-2000.pdf)

The work group plans to release a first draft of the standard for broad public review in late July and to have a second draft available in September at approximately the same time OPS has indicated that a final rule will be published. The September draft of the standard will need to be modified to incorporate changes resulting from OPS deliberations on the comments under this docket and codified in the final rule. We are striving to complete the integrity standard within 60 days of the publication of the final rule so that it will be available to companies as they develop their integrity management plans in 2001."

New Inspection Forms

The DOT / OPS has re-evaluated their inspection process, based on information gleaned from previous accident investigations and input from subject matter experts. They have begun using a revised set of forms during their pipeline inspections, which are intended to address broader pipeline management and integrity issues. The new forms can be downloaded directly from the DOT / OPS website at http://ops.dot.gov/forms.htm.

Pending Audits?

Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency's latest standards.

Unusually Sensitive Areas (USA) Comments

The docket for USAs (#5455) has also been very active, with comments due by June 27, 2000. The definition of USAs will have a ripple effect on the pipeline industry. For example, USAs are included in the currently proposed definition of High Consequence Areas. Of particular interest are the comments submitted by the American Water Works Association (AWWA), whose membership supplies water to 80% of the people in the nation. They want the DOT to "designate all drinking water supplies as USAs". This would increase the number of USAs. The AWWA also proposes that Source Water Assessment Plans (SWAPs) be used to designate the area requiring protection, not just the Wellhead Protection Area. This would increase the amount of area that would be considered a USA.

Letters of Interpretation You May Have Missed

In-plant piping that crosses a railroad has been the subject of much discussion over the past few years. The preamble to a June 28, 1994 federal register publication stated that in-plant piping could cross a single public thoroughfare, but that it could not cross a railroad. This position was repeated in an October 24, 1994 letter of interpretation. However, on November 18, 1998, the DOT/OPS issued a new letter of interpretation that evaluated the issue in more detail and concluded "we will consider the thoroughfare interpretation of in-plant piping system to include in-plant railroad crossings". These letters of interpretation, along with 1,200 hundred others, are available on www.DOTPipeline.org, where they can be searched by keyword. To find these letters of interpretation, search for the keyword "railroad", and select just Part 195 on the search screen. (note – we have heard from some Netscape Navigator users that they have had some problems with that site, which our webmaster is investigating.)

Drug Testing Guidance and the Operator Qualification 4-part Test

Can Drug Testing Guidance help answer Operator Qualification 4-part test?

Unlike the Operator Qualification rule, which is new and untested, the DOT Drug and Alcohol Testing rules have been in place since 1988. Volumes of guidance have been created concerning the applicability of the drug and alcohol testing rules to various persons and activities. While the drug testing rule has a larger scope than the OQ rule (for instance, drug testing covers emergency response activities and LNG facilities, both of which are not covered by the OQ rule), there are many similarities in the application of the 2 rules:

The drug and alcohol testing rules in 49 CFR Part 199 define a "covered function" as "an operations, maintenance, or emergency response function conducted on the pipeline or LNG facility that is regulated by Part 192, 193, or 195".

The Operator Qualification rules define a "covered task" as a task that is "an operations and maintenance task" (question 2), "performed on a pipeline facility" (question 1), and "performed as a requirement of this part" (question 3).

If the same logic is applied to the OQ rule as to the drug testing rule, the following activities would be "covered tasks":

  • replacement of pipe, even if the work does not include making the tie-in to the operating pipeline
  • serving as a "call-out" employee to do initial inspection and reset of a facility which has had an alarm
  • performing UT, radiographic, and magnetic flux tests on a pipeline
  • conducting and witnessing hydrostatic tests of a pipeline, when the test is performed for operations or maintenance reasons
  • control of pipeline pressure by a refinery operator
  • opening / closing valves on a pipeline to change the source of gas to the pipeline

Changes at OPS Headquarters

Rich Felder, the Associate Administrator for Pipeline Safety, left that post on June 16 and is now working on the Common Ground initiatives. Stacey Gerard, Director of the Office of Policy, Regulations, and Training, is Acting Associate Administrator until a new Associate Administrator is named.

Acquiring a pipeline?

RCP can provide due diligence audits to help you ensure that potential compliance issues have been addressed before the sale is final.

OCS Decommissioning Rule Proposal

On July 7, 2000, the Minerals Management Service (MMS) proposed amendments to its regulations governing oil and gas operations in the Outer Continental Shelf (OCS) to update decommissioning requirements (65 FR 41892). These regulations apply to decommissioning of pipelines, in addition to other OCS facilities. The regulations allow for pipelines to be decommissioned "in place" with the Regional Supervisor's approval. Among other requirements, the operator must flush the line; fill the line with seawater; cut and plug each end, and bury each end at least 3 feet below the seafloor (or cover with protective concrete mats, if required by the Regional Supervisor). The operator must also remove all valves and other appurtenances that could unduly interfere with other uses of the OCS. The MMS will consider all comments received by October 5, 2000.

Texas Announces New Oil Spill Penalties

Texas Land Commissioner David Dewhurst has announced revised penalty guidelines for oil spills in Texas coastal waters. Beginning August 1 spills less than a gallon will draw fines of $250. Larger spills will draw fines up to $500 plus $250 per barrel of oil spilled. Penalties for failure to report a spill will range from $500 to $25,000 per day.

"Basic protection of our coastal environment requires that we create a powerful incentive to handle oil carefully and report spills promptly," Dewhurst said. According to the Commissioner, more than 1,200 oil spills were reported in Texas waters last year.

The new guidelines were developed by a task force made up of industry representatives, environmental groups, and GLO staff. The new scheme also includes incentives. Companies with a "Sound Management Practice Program" will receive reduced assessments when spills occur.

The new guidelines are posted on the Land Office web site, http://www.glo.state.tx.us/oilspill, as well as in the June 23 edition of the Texas Register at http://lamb.sos.state.tx.us/texreg/.

Help Wanted

Know someone with regulatory expertise who is interested in full or part time work? Our recruiting coordinator would be glad to get their resume! Have them sent to marilyn@your-rcp.com, or FAX to 713-655-8083.

Visit Regulatory Compliance Partners on the Web at

http://www.your-rcp.com

or give us a call at 1-888-RCP-X-YES to see what we can do for you.

Ongoing Resources

These articles are maintained and updated as new information becomes available.

Last Updated: October 2026

Regulatory Watch: Key Dates & Deadlines

Welcome to Regulatory Watch! In this monthly update, we’ll keep you informed on proposed rule comment periods, effective dates, and upcoming deadlines for various compliance requirements.

2137-AF63Proposed Rule Stage

Administrative Rulemaking Regulatory Procedures

Proposed
Final
Implementation
Regulatory Agenda2137-AF63
Federal Register DocumentPHMSA-2026-1555
Regulatory WatchImplementation Stage

All Liquid HCA segments capable of ILI § 195.452(n)

Proposed
Final
ImplementationJul 2, 2040
Regulatory AgendaNot available
Federal Register DocumentNot available
2137-AF45Proposed Rule Stage

Amendments to Liquefied Natural Gas Facilities

Proposed
Final
Implementation
Regulatory Agenda2137-AF45
Federal Register DocumentPHMSA-2019-0091
2137-AF61Final Rule Stage

Cost Recovery for Siting Reviews for LNG Facilities

Proposed
Final
Implementation
Regulatory Agenda2137-AF61
Federal Register DocumentPHMSA-2022-0118
2137-AF51Final Rule Stage

Gas Pipeline Leak Detection and Repair

Proposed
Final
Implementation
Regulatory Agenda2137-AF51
Federal Register DocumentPHMSA-2021-0039
Regulatory WatchImplementation Stage

Gas Transmission: Assessments Outside HCAs § 192.710

Proposed
Final
ImplementationJul 3, 2034
Regulatory AgendaNot available
Federal Register DocumentNot available
2137-AF37Proposed Rule Stage

Oil Spill Response Plans, Accident Notifications, Inspections and Investigations and other Miscellaneous Pipeline Safety Changes

Proposed
Final
Implementation
Regulatory Agenda2137-AF37
Federal Register DocumentPHMSA-2018-0047
2137-AF52Proposed Rule Stage

Pipeline Operational Status

Proposed
Final
Implementation
Regulatory Agenda2137-AF52
Federal Register DocumentNA
2137-AF44Proposed Rule Stage

Repair Criteria for Gas and Hazardous Liquid Pipelines

Proposed
Public comments ClosedCloses Sep 8, 2026
Final
Implementation
Regulatory Agenda2137-AF44
Federal Register DocumentPHMSA-2025-0019
2137-AF60Proposed Rule Stage

Safety of Carbon Dioxide and Hazardous Liquid Pipelines

Proposed
Final
Implementation
Regulatory Agenda2137-AF60
Federal Register DocumentNA
2137-AF53Final Rule Stage

Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives

Proposed
Final
Implementation
Regulatory Agenda2137-AF53
Federal Register DocumentPHMSA-2021-0046

Sprint I & II Update

To further the Administration’s deregulatory policies, PHMSA has published in today’s Federal Register twenty-eight (28) separate rulemaking actions affecting the pipeline safety regulations (PSR; Parts 190-199). Click here to access the documents.

Rulemaking Description Stage Code
Pipeline Safety: Rationalize Special Permit Conditions PHMSA proposes to amend its special permit procedures to ensure permit conditions are directly tied to the specific pipeline safety regulations being waived. NPRM 49 CFR Part 190
Pipeline Safety: Rationalize Calculation of Regulatory Filing and Compliance Deadlines PHMSA will clarify that regulatory filing and compliance deadlines falling on weekends or Federal holidays automatically move to the next business day. DFR 49 CFR Part 190
Pipeline Safety: Adjust Annual Report Filing Timelines PHMSA will amend annual reporting requirements to move the gas pipeline annual report submission deadline from March to June. DFR 49 CFR Part 191
Pipeline Safety: Property Damage Definition for Incident Reporting PHMSA will clarify incident reporting property damage calculations for gas pipelines and update hazardous liquid accident reporting thresholds using inflation-adjusted criteria. DFR 49 CFR Parts 191 & 195
Pipeline Safety: Exception for In-Plant Piping Systems PHMSA proposes to clarify that in-plant piping systems are not subject to federal pipeline safety regulations. NPRM 49 CFR Part 192
Pipeline Safety: Codify Enforcement Discretion on Incidental Gathering Lines PHMSA proposes to codify enforcement discretion clarifying that restrictions on the historical incidental gathering line exemption apply only to newly constructed lines. NPRM 49 CFR Part 192
Pipeline Safety: Eliminate Burdensome Coating Assessment Deadlines PHMSA proposes to replace prescriptive deadlines for coating damage assessments and remediation with a requirement that activities be completed before the pipeline is placed in service. NPRM 49 CFR Part 192
Pipeline Safety: Atmospheric Corrosion Reassessment for Pipeline Replacements PHMSA proposes to remove the 3-year reassessment interval following replacement of atmospheric corrosion defects and allow use of the standard 5-year reassessment interval. NPRM 49 CFR Part 192
Pipeline Safety: Harmonize Class Change Pressure Test Requirements PHMSA proposes to reduce the minimum pressure test duration following certain class location changes from 8 hours to 4 hours, aligning with existing Subpart J requirements. NPRM 49 CFR Part 192
Pipeline Safety: Clarify MAOP Reconfirmation Testing Records PHMSA will issue a technical correction clarifying that operators may use pre-1970s pressure test records when reconfirming MAOP under §192.624. Final Rule 49 CFR Part 192
Pipeline Safety: Remote Sensing Technologies for ROW Patrols PHMSA will explicitly allow right-of-way patrols to be conducted using unmanned aircraft systems, satellites, and other remote sensing technologies. DFR 49 CFR Parts 192 & 195
Pipeline Safety: Technical Standards Updates and Amendments PHMSA will update incorporated standards and make technical amendments in response to an industry petition for reconsideration. Final Rule 49 CFR Part 192
Pipeline Safety Program: Update of Standards Incorporated by Reference PHMSA issued multiple direct final rules updating incorporated industry consensus standards used throughout Parts 192 and 195, replacing outdated editions with current versions. Multiple DFRs 49 CFR Parts 192 & 195

The following is a summary of the 40 rulemakings that PHMSA published in the Federal Register on April 24, 2026. If any adverse comment is received to a DFR PHMSA must rescind the rule and repropose. Click here to access the documents.

Rulemaking Description Stage Code
Pipeline Safety and Hazardous Materials Safety: Amendments to PHMSA Procedural Regulations PHMSA proposed miscellaneous amendments to procedural regulations governing informal rulemaking for both pipeline safety and hazardous materials programs. NPRM 49 CFR Part 190
Pipeline Safety: Interpretation Request Procedures PHMSA amended interpretation procedures to require publication of interpretation requests on its website and provide an opportunity for public comment. Final Rule 49 CFR Part 190
Pipeline Safety: Declaratory Order Procedures PHMSA established formal procedures for issuing declaratory orders through a new section in Part 190. Final Rule 49 CFR Part 190
Pipeline Safety: Consent Orders PHMSA clarified that consent agreements may be used to resolve enforcement actions, including cases involving civil penalties. Final Rule 49 CFR Part 190
Pipeline Safety: Adjustment to OPID Notifications for Construction PHMSA proposed adjusting the inflation-based threshold that triggers OPID notifications for certain construction and facility modification activities. NPRM 49 CFR Part 191
Pipeline Safety: Eliminating Limitations on Welders and Welding Operators PHMSA proposed allowing welders qualified through non-destructive testing methods to perform compressor station welding activities currently subject to additional restrictions. NPRM 49 CFR Part 192
Pipeline Safety: Material Properties Verification During MAOP Reconfirmation PHMSA proposed clarifying that material testing at pressure test manifold sites is not required when traceable, verifiable, and complete material records already exist. NPRM 49 CFR Part 192
Pipeline Safety: Electronic Retention of Part 194 Response Plans PHMSA amended regulations to allow operators to maintain electronic copies of response plans instead of paper copies. DFR 49 CFR Part 194
Pipeline Safety: Remote Monitoring of Rectifiers PHMSA proposed allowing remote monitoring technologies for rectifiers used in external corrosion control programs. NPRM 49 CFR Part 195
Pipeline Safety: Clarifying Hazardous Liquid High-Consequence Area Designations PHMSA amended HCA guidance to clarify spill considerations in agricultural fields and reorganize threat identification guidance. DFR 49 CFR Part 195
Pipeline Safety: Timeframe to Make Rupture-Mitigation Valves Operational PHMSA proposed extending the deadline for placing rupture-mitigation valves into operation from 14 days to 90 days after a pipeline enters service. NPRM 49 CFR Part 192
Pipeline Safety: Hazardous Liquid Valve Maintenance Schedule PHMSA proposed allowing operators to implement risk-based valve maintenance schedules, subject to a maximum inspection interval of one year. NPRM 49 CFR Part 195
Pipeline Safety: Property Damage Definition for Incident Reporting PHMSA proposes revising property damage thresholds for reportable gas and hazardous liquid pipeline incidents and clarifying applicability to telephonic notifications. NPRM 49 CFR Parts 192 & 195
Pipeline Safety: Remote Sensing Technologies for ROW Patrols PHMSA proposes clarifying that unmanned aerial systems, satellites, and other remote-sensing technologies may be used to satisfy right-of-way patrol requirements. NPRM 49 CFR Parts 192 & 195
Pipeline Safety: Adjust Annual Report and NPMS Filing Timelines PHMSA proposes extending annual report and NPMS submission deadlines for gas pipeline and storage operators to June 15 each year. NPRM 49 CFR Part 191
Pipeline Safety: Editorial Corrections and Clarifications PHMSA issued multiple final rules correcting editorial errors, updating references, removing obsolete submission methods, and improving regulatory clarity. Final Rules Various
Pipeline Safety: Update of Standards Incorporated by Reference PHMSA issued multiple direct final rules updating incorporated industry consensus standards, including NFPA, ASTM, MSS, NACE, and ASME standards. Multiple DFRs 49 CFR Parts 192 & 195

Have questions about an upcoming deadline? Please reach out to Jessica Foley for assistance!

Last Updated: October 2026

Conference News

Jan252027

Pipeline Pigging and Integrity Management Conference

▦ January 25, 2027 – January 28, 2027⌖ George R. Brown Convention Center, Houston, TX

The 39th International Pipeline Pigging & Integrity Management Conference (PPIM) will take place at the George R. Brown Convention Center in Houston. The event brings together pipeline operators, engineers, and industry professionals to explore advancements in pipeline inspection, integrity management, risk assessment, and emerging technologies.…

ExhibitingBooth 524
RCP Team Attending
Heather RoarkHeather RoarkSales & Marketing Coordinator
Jessica FoleyJessica FoleyVice President
Featured Presentations
Topic to be determined
Chris McLaren
Chris McLarenExecutive Consultant
October 27, 2026 at 7:30 AM
Event Details
Last Updated: October 2026

PSI Training Schedule

Date Training Course Price Registration
Nov 17 – Nov 19, 2026 DOT Pipeline Compliance Workshop $2,150 SOLD OUT
Feb 16 – Feb 18, 2027 Pipeline Safety Audit Training $2,150 Register →
Feb 23 – Feb 25, 2027 Advanced Pipeline Risk Assessment Workshop $2,150 Register →
Mar 23 – Mar 25, 2027 DOT Pipeline Compliance Workshop $2,150 Register →

WEBINAR RECORDING!
Unpacking the Key Updates in API RP 1170 & 1171, 2nd Edition

RCP and the Pipeline Safety Institute offered a free webinar exploring the 2nd Editions of API RP 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage and API RP 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs. Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!

WEBINAR RECORDING
Pipeline Safety: Unpacking the Class Location Change Requirements

Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!

You asked and we listened!

Advanced DOT Pipeline Compliance Workshop is on the calendar!

This intensive and interactive 3-day, in-person workshop is designed for those who have previously completed our DOT Pipeline Compliance Workshop and are ready to take their knowledge to the next level.

New Workshop Alert!

Prepare Your Team for Pipeline Safety Audits with Confidence!

Our 3-day Pipeline Safety Audit Workshop is tailored for professionals responsible for the safe operation of hazardous liquid and natural gas pipelines. Designed for groups of 10-15 participants, this interactive training…

On-Site Training Request

We have conducted on-site training for oil and gas companies for over 25 years and can provide customized workshops for companies with groups of five or more.

We would welcome the opportunity to discuss our services with you.

Sincerely,

W. R. (Bill) Byrd, PE
President
RCP Inc.

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