1. ASME B31Q Update & Perspectives Warren Miller
Hello, I am Warren Miller. If you don’t know me, you may know my brother Lane Miller. I am the one he talks about sometimes.
I retired from PHMSA just 7 months ago, after 22 ½ years of inspection, regulation and liaison work with the agency. One of the projects I was and still involved in is OQ. Today I want to give you an update on and discuss ASME B31Q. Please ask questions and hopefully I can answer them.

2. DISCUSSION AGENDA Overview of ASME B31Q Updates of B31Q
Current uses by Industry
Perspective of Operators
Perspective of Regulators
readout

3. ASME B31Q Overview
Scope covers tasks that impact the safety or integrity of the pipeline
Technically based
Prescriptive and Performance options
192/195 requirements are considered
Not a regulatory document
Intended for international use
The scope of safety and integrity derives more covered tasks than the 4 part test. New construction is also included.
The standard specifically addresses portability of an individuals qualification to perform covered tasks.
A technically based standard that has both prescriptive and performance options
The pipeline safety regulations are considered but not the total driving force behind the standard
Currently, this standard is being utilized outside of the United States.

4. ASME B31Q Overview Standardized task list (168 total)
Standardized reevaluation frequencies
Identifies key qualification components
Allows for portability
Includes participation by all areas of industry
The list contains approximately 40 diving tasks.
The standardized reevaluation intervals were determined without the frequency of the performance of the covered task
Participation is encouraged from all of industry; transmission and distribution, gas and liquid, contractors, unions, and regulators

5. B31Q Future Changes New technology Regulation changes
Long-term degradation of physical abilities
New appendix for interpretations
Moving generic AOC list to other standards
Develop out the 40 diving tasks
Changes in this standard is driven by different components.
New technology and regulatory changes will cause amendments and additions to the covered task list, as well as recommendations from the industry.
Discussions have delicately addressed long-term degradation of physical abilities – such as a 30 year welder… his eyes will not be as good as they were. An individuals’ strength is another – such as needed for turning emergency valves.
Although not many interpretations of the standard have been requested, the committee is reviewing how to display them with the standard.
General AOCs have been discussed to the point of requesting B31.4 and B31.8 to require general AOCs for anyone that comes out onto the ROW, not just qualified personnel. Everyone needs to be able to recognize and react, even just to run. Technically it makes no sense to be on the ROW without the knowledge of what could hurt me.
The final 40 tasks in the standard – diving – will be developed out with the same format that you will see in a few of slides.

6. B31Q – You can Assist Comments to secretary Work through members
Attend meetings
Upcoming meetings
San Diego, CA: Sept , 2014
New Orleans, LA: February 24-25, 2015
Web site:
Search on B31Q Committee
You can have input by making comments through the standard secretary, contacting current members, or you can attend the meetings. I will warn you: We put everyone who comes to these meetings to work.
The next couple meetings are -----
You can also find out from the webpage where we are meeting next.

7. Updates of B31Q Current version out June 30, 2014
Greatest change was the further development of the covered tasks
Built in components to address task specific issues/AOCs
Remained out of “procedure” depth while revising the covered tasks.
As of June, the 2014 version of the standard has been available.
Biggest changes is the standard was amending the covered tasks to enhance the task criteria.

8. This is a sample of the revision that took place from 2010 to 2014
This is a sample of the revision that took place from 2010 to As you can see, the committee developed those areas that if addressed correctly should eliminate most AOCs.
Explain the page

9. Current Uses by Industry
Numerous operators are using B31Q
Instances of cost savings
Covered tasks review
Other operators have adopted certain parts of the standard
Covered task list
Evaluator requirements
Some operators have adopted the standard and have been able to show cost savings where less materials were used due to performance of a qualified individual. Some operators have seen where costs to do it right the second time is 3.5 times more than doing it correctly the first time.
If you do adopt, do the covered task review to ensure that you do not drop a covered task that is required by the regulation that is not addressed in B31Q.
Some other operators have used portions of the standard to develop or enhance their OQ program. Again make sure that your final OQ program meets the minimum requirements of the regulations.

10. Perspective of Operators
Gas and Liquid operators are split on use
In general – in 2005/2006
Some operators making changes now
Most operators will not adopt B31Q until it is required by law
Incorporated by reference
Additional costs
When this standard came out originally, interstate gas transmission and APGA wanted the whole standard incorporated while liquid industry and AGA did not want it at all. That split division caused PHMSA to wait and review the OQ programs as they developed.
For the most part, liquid companies do not want to use B31Q because of programs they had already developed in relation to PSM (process safety management) requirements. Some operators have begun looking at B31Q as a viable document for use.
As seen, most operators will not use B31Q or any other standard until mandated. I have visited with a number of operators who like B31Q and would use it, but if not a regulatory requirement, upper management will not entertain changing programs or spending extra money.

11. Perspective of Regulators
General belief that B31Q is a good guidance document for development and maintenance of an OQ program
The standard addresses:
New construction
Evaluators
Training
Program effectiveness
The document was developed from a large group of operators, contractors, and regulators. This standard had more regulatory representation that any other standard in history – 5 federal and 5 state representatives. Currently 3 federal and 4 state reps still sit on the committee.
Where the pipeline regulations do not address certain areas, the standard does:
New construction has been a contentious point since the regulation came into effect. A number of states now require new construction to be addressed with OQ, some even quality management,
The need for effective evaluators is another point the regulation does not address. The standard goes into good detail about needed parameters. Evaluators are a continued point of discussion as it relates to contract employees… company employees also. Trying to maintain a valid consistent OQ program should be your goal.
Training – this is where OQ got its birth. Back in 1994, RSPA introduced and NPRM on training in response to Congress and operator nixed it with comments. Now NTSB has not accepted the current regulation as addressing training correctly. The standard provides direction in using training.
Program effectiveness is required in every program in pipeline safety except OQ. The standard addresses the need and direction for reviewing an OQ program to determine if it is working effectively.

12. What Does the Future Hold for OQ?
QO implementation – October 28, 2002
Public meetings – 2003, 2005, 2006
Continuing incidents and accidents with operator error
Basic construction violations continue to be found during inspection
Retirements and brand new personnel in the workforce
Training issues
OQ is now almost 14 years old and is the most far reaching program an operator can have as it encompasses most day to day work. There are still areas for improvement. There are still incidents and accidents occurring across the country due to operator error.
Basic construction issues and violations continue to be found by federal and state inspectors. As an inspector, one question that I always left a site with was “what would I have seen if they had not known I was coming today?’
The workforce is changing across the country, maybe not in your companies yet, but it is happening. Companies are losing mentors and experience and hiring personnel that are new to the industry.
Generational differences make training a challenge and is seen where some companies have 4 sometime 5 generations in a workplace. Where someone like me likes to use a notebook, calculator and pencil to do a test, someone much younger may do best on an Iphone.
OQ will be changing. There are drafts of rule changes being looked at and an ANPRM or NPRM will be coming in the future.
I would two questions of you, but don’t answer me out loud Have you amended your OQ program since you first developed and implemented it? Have you reviewed it for effectiveness?

13. QUESTIONS?
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THANK YOU FOR SPENDING YOUR TIME WITH ME TODAY. DOES ANYONE HAVE QUESTIONS?

14. Senior Regulatory Compliance Specialist
Thank You!
THANKS FOR YOUR PARTICIPATION.
Warren Miller
Senior Regulatory Compliance Specialist