On November 15, 2021, PHMSA published the Final Rule that revises 49 CFR Parts 190-199 to improve the safety of onshore gas gathering pipelines. Pipeline Accident Prevention Service (PAPS) has reached out to PHMSA and the Railroad Commission of Texas to verify our interpretation on how this Final Rule impacts Type C and Type R Gathering Lines in regard to Operator Qualification requirements and Drug & Alcohol requirements.
For Operator Qualification, personnel working on Type C and R Gathering Lines are not required to be compliant with Part 192, Subpart N. In their published FAQs (link below), PHMSA states a prudent operator should ensure personnel are adequately trained and capable of safely performing their assigned tasks; however, they are not subject to Part 192.
For Drug and Alcohol, personnel working on Type C Gathering Lines are required to be compliant with Part 199 and 40. Any person performing a covered function as defined in 199.3 must be included in a DOT Drug & Alcohol Program. Conversely, Type R Gathering lines are not required to be compliant with Part 199 and 40.
PHMSA FAQ link as follows:
CFR Part 199.3 as follows
PAPS can help your organization to meet Operator Qualification and Drug & Alcohol requirements. Call us at (281) 379-1130 or contact us via email by clicking HERE.