PHMSA 9 Protocols: Form 14 (Numbers 17 & 19)
Continuing EWN's coverage of PHMSA's 9 OQ Inspection Protocols and Form 14, this post covers Protocol Numbers 17 and 19 — two elements focused on personnel performance monitoring and program performance improvement.
Protocol 17: Personnel Performance Monitoring
Under 49 CFR 192.805(d)(e), Protocol 17 requires operators to evaluate an individual's qualifications when there is reason to believe the individual's performance of a covered task contributed to an incident, or when the operator has reason to believe the individual is no longer qualified.
This is a critical safeguard: the OQ program is not just about initial qualification, but about ongoing monitoring. When incidents occur or performance concerns arise, operators must act and re-evaluate the individual's qualifications.
Protocol 19: Program Performance and Improvement
Under 49 CFR 192.605(a), Protocol 19 requires that operators review and update their written procedures manual at intervals not exceeding 15 months , with at least one review per calendar year. This ensures that the OQ program remains current with regulatory changes, operational changes, and lessons learned from incidents and near-misses.
Operators should ensure that their OQ program documentation reflects these ongoing review and update obligations. For more information on PHMSA's OQ Inspection Protocols, visit the PHMSA website or contact EWN.
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