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Issued: September 15, 2006
Background
The transmission and distribution of gas and hazardous liquids in pipelines is one of the safest forms of transportation. However, investigations of pipeline accidents from 1975 through 1986 revealed that human error was a contributing factor to some failures. The failures prompted the United States National Transportation Safety Board (NTSB) to make explicit recommendations for the training, testing and qualification of pipeline employees in 1987. The qualification of pipeline personnel is an important measure against failures caused by human error.
The development of the B31Q standard originated from the need for the pipeline industry to take a rational and technical approach to operator qualification (OQ) and from regulatory actions in the United States from 1987 through 2003. In 1987, the United States Department of Transportation (DOT) issued a notice inviting public comment on the need for additional regulations or a certification program for the qualification of personnel who design, construct, operate and maintain gas or hazardous liquid pipelines. Shortly thereafter, work began in the United States Congress to amend the Pipeline Safety Laws to include OQ requirements. The Pipeline Safety Act of 1992 included language requiring that personnel responsible for the operation and maintenance of pipelines be tested for qualifications and certified to operate and maintain those pipelines.
In response to this congressional action, DOT published a Notice of Proposed Rulemaking (NPRM) in 1994 to establish specific training requirements for the qualification of pipeline workers. This training rule met with varying responses including a petition for withdrawal of the NPRM from pipeline industry representatives. Subsequently, Congress amended the 1992 law with the Pipeline Safety Improvement Act of 1996 requiring simply that individuals who operate or maintain pipelines be qualified. In addition, this Act required that these qualifications address the ability to recognize and react appropriately to abnormal operating conditions that may indicate a potentially dangerous situation or a condition exceeding design limits. In 1996, DOT withdrew the 1994 proposed rulemaking and simultaneously issued a notice to form a negotiated rulemaking committee (RegNeg Committee) to develop a final rule on the qualification of pipeline personnel.
The negotiated rulemaking process was intended to provide an opportunity for affected parties to present their views and reach a consensus on a proposed qualification rule. The RegNeg Committee members came from various organizations representing broad interests including industry, government, labor and the public. The committee met several times from 1997 through 1999, when consensus on the final rule was reached.
The Final Rule on the Qualification of Pipeline Personnel was issued by DOT on August 27, 1999. This rule delineated the essential elements of a qualification program, and the scope was limited to a four-part test for covered tasks. It also set timeframe for the development of the operators’ qualification programs, and the completion of initial qualification of pipeline personnel in 2002.
The Final Rule was not prescriptive, and the resulting flexibility built into the performance-based rule made it difficult to measure operator compliance. This led to the development of “protocols” to assist regulators in the evaluation of qualification programs. Protocols were finalized after a series of public meetings in 2003; however, differences still existed between the pipeline industry and DOT regarding the implementation, inspection and subsequent enforcement of the OQ rule. Both groups committed to the development of a national consensus standard on personnel qualification, where the outstanding issues could be resolved.
The pipeline industry approached ASME to sponsor the development of a consensus standard on pipeline personnel qualification. The ASME Code for Pressure Piping, B31 Committee formed the B31Q Project Team on Qualification of Pipeline Operators. This project team met for the first time in August 2003 and began the development of a technically based consensus standard for the qualification of pipeline personnel.
The ASME B31Q Project Team included representatives from federal and state regulatory agencies, contractors, industry associations, labor and three industry sectors – hazardous liquid, gas transmission, and local distribution companies. The project team met regularly over a period of twenty months to reach consensus on the content of the standard. Additional resources, including Subject Matter Experts, industry associations and service providers were utilized regularly. In all, over 100 people worked diligently to retain as much of the existing framework of OQ as was feasible and to develop a technically based standard, recognizing the diverse needs of the industry and regulators. The consensus process was completed with approval of B31Q as an American National Standard on July 10, 2006. ASME published B31Q on September 15, 2006.
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