RFP #2018-078 PUC Safety Division Safety Database ... PUC 2018-078...Section Referencing # QUESTION...

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Section Referencing # QUESTION ANSWER Appendix C-2 Q‐1 Please provide a link to where the business requirements referenced in Appendix C-2 can be found. Attached to this Vendor Inquiry Response and located within the RFP as an attachment in the pdf. Section 2 Schedule of Events Q‐2 The schedule of events has the Anticipated Notice to Proceed slated for 12/7/17. What is the Go Live date? Go live will have to be within one year from start of project. Section A-3 Q‐3 If we are working with Carahsoft for the RFP. Does my organization need to be registered with the State of NH? A subcontractor for a Vendor does not need to be registered with the State of New Hampshire. However the Vendor submitting the proposal (Carahsoft) will need to be registered with the state. Q‐4 Please confirm that the legacy system is based in SQL Server, contains fewer than 10,000 total records and that the State is presently working on data cleansing. Yes, it is in SQL Server 2008 R2 and there are 8500 records between DigSafe and Inspections. The state will be normalizing the database and cleansing the data. Appendix C-2 Q‐5 Please confirm that the only point of system-to-system integration intended is from the selected solution to FHMSA. If other integrations are in scope, please provide detail. a. Integration with PHMSA will not be occurring. Rather the expectation is to export information to PHMSA’s customized software called “Inspection Assistant”. The frequency of the exportation has not been determined as of yet. It may be daily, weekly, monthly or annually. For more information on PHMSA’s Inspection Assistant software please refer to user training videos provided in the following link view at https://vimeopro.com/iatraining/topical-screencasts/video/197349023. These are used to assist federal inspectors. b. The expectation is to have the GEO code capabilities associated with the mobile solution so locations of inspections can be imported or integrated into an existing ESRI Arc Info GIS information system. This is a preferable capability but not a prerequisite. c. Additionally, calendaring integration to be compatible with PUC current on premise exchange environment (Microsoft or near future expected Microsoft Office 365 solution. d. Preference would like to have file share integration from Cloud to existing network drives if possible. RFP #2018-078 PUC Safety Division Safety Database Questions & Answers Vendor Conference October 6th, 2017

Transcript of RFP #2018-078 PUC Safety Division Safety Database ... PUC 2018-078...Section Referencing # QUESTION...

  • Section Referencing # QUESTION ANSWER Appendix C-2 Q1 Please provide a link to where the business requirements referenced in Appendix C-2 can be found.

    Attached to this Vendor Inquiry Response and located within the RFP as an attachment in the pdf.

    Section 2 Schedule of Events Q2 The schedule of events has the Anticipated Notice to Proceed slated for 12/7/17. What is the Go Live date? Go live will have to be within one year from start of project.

    Section A-3 Q3 If we are working with Carahsoft for the RFP. Does my organization need to be registered with the State of NH?

    A subcontractor for a Vendor does not need to be registered with the State of New Hampshire. However the Vendor submitting the proposal (Carahsoft) will need to be registered with the state.

    Q4Please confirm that the legacy system is based in SQL Server, contains fewer than 10,000 total records and that the State is presently working on data cleansing.

    Yes, it is in SQL Server 2008 R2 and there are 8500 records between DigSafe and Inspections. The state will be normalizing the database and cleansing the data.

    Appendix C-2 Q5Please confirm that the only point of system-to-system integration intended is from the selected solution to FHMSA. If other integrations are in scope, please provide detail.

    a. Integration with PHMSA will not be occurring. Rather the expectation is to export information to PHMSAs customized software called Inspection Assistant. The frequency of the exportation has not been determined as of yet. It may be daily, weekly, monthly or annually. For more information on PHMSAs Inspection Assistant software please refer to user training videos provided in the following link view at https://vimeopro.com/iatraining/topical-screencasts/video/197349023. These are used to assist federal inspectors. b. The expectation is to have the GEO code capabilities associated with the mobile solution so locations of inspections can be imported or integrated into an existing ESRI Arc Info GIS information system. This is a preferable capability but not a prerequisite. c. Additionally, calendaring integration to be compatible with PUC current on premise exchange environment (Microsoft or near future expected Microsoft Office 365 solution. d. Preference would like to have file share integration from Cloud to existing network drives if possible.

    RFP #2018-078PUC Safety Division

    Safety DatabaseQuestions & Answers

    Vendor Conference October 6th, 2017

  • Section Referencing # QUESTION ANSWER

    Q6 It was mentioned that all forms and letters are available for vendor review. Please provide detail as to how/where to access these samples.

    Attached to this Vendor Inquiry Response are zipped files with the forms (documents and spreadsheets) and letters for review. Also attached is an example of a completed filled report. For general information on types of data collected helpful information can be found from the PUC Safety Division website https://puc.nh.gov/Safety/safety.htm. Enforcement Data is shown by scrolling on the left menu and clicking on hyperlinks.

    Appendix C-2 Q7For requirement A2.14, The application must allow a human user to explicitly terminate a session. No remnants of the prior session should then remain. Please explain the intent of this requirement.

    It is a standard DoIT security policy requirement that all web applications apply Application Layer Gateway Security. So this is requiring that the user be able to terminate the session without any in session information left available to an unauthorized user.

    Q8 What hardware/devices will be used in the field? Are there any existing standards for voice to text that must be supported?

    We are expecting to utilize Surface Pro tablets or IPad Air 2s and IPhones and on occasion laptops. The expectation is the software solution should be compatible with the current market leaders of mobile platforms. Presently, there are not existing standards for voice to text at this time.

    Q9

    Please confirm that the State does not have a preferred document management solution (DMS). It was stated that document/file storage in a DMS or natively in the solution are both acceptable approaches. Please confirm.

    Please note we envision the proposed software solution to not be a document management solution but more of a CRM type application.

    Q10 Please confirm that vendors may format narrative responses to the Appendices on vendor letterhead.Yes. The narratives responses may use vendor letterhead as long as the intended section (s) referenced within the RFP are clearly identified.

    Q11 Please publish a list of in-person and phone attendees at the pre-bid conference, if possible.Attendees: Cindy Dotlich, Randy Knepper, Irene Koffink, Jay Joplin, Eunice Landry, Randy Arrant and Vendors.

    Q12

    It was stated during the conference that the cost and technical proposals should be submitted separately. Section 4 of the RFP does not mention this. Please confirm that they must be submitted separately, and confirm the number of originals, copies, and CD ROMs required for each.

    a. Section 4.17 is meant to be interpreted that the Cost Proposal shall be contained in Respondents Section VII Cost Proposal and shall not be embedded within Section III or any other sections. Please note the Cost Proposal shall follow the format as described in Appendix F Pricing Worksheets.b. Please reference section 4.1 (page 16 of RFP) for the requirements of 1 original and 8 copies, one transmittal form (page 23 of RFP) and CD Rom requirement.

  • Section Referencing # QUESTION ANSWER

    Appendix H-25: GENERAL CONTRACT REQUIREMENTS.H-25.5 - Vendor StaffThe State, at its sole expense, may conduct reference and background checks on the Vendors Project Staff

    Q13

    We assume this only applies to Vendors project personnel that are performing the solution implementation services and not the Cloud Service Provider (CSP) personnel that are hosting the solution.For example, CSP engages the services of a background screening vendor to conduct background checks on employees at the time of hire in the U.S. CSP also performs background investigations in certain foreign countries. The scope of these checks is subject to local laws in the jurisdictions in which the employee is hired. Can PUC please modify this requirement accordingly to not apply to the CSP personnel?

    Per section 4.15 of the RFP, the PUC cannot modify this requirement. However, this requirement is directed at the vendor providing the customized solution and not the Cloud Service Provider.

    H-25.12.14 DATA BREACH In the event of a Data Breach, the Vendor shall comply with provisions of NH RSA chapter 359C:20.

    Q14

    In the event of a security breach and if negotiated in the agreement, the Cloud Service Provider (CSP) can notify PUC identified points of contact. The CSP cannot notify affected parties because the CSP does not view PUC data. The CSP is responsible for maintaining access in terms of performance and availability to the data. The data is owned by PUC.

    As such, we would like to request the requirements for breach notifications should align with the existing CSP reporting requirements that also align with FedRAMP.

    This can be negotiated during the contract phase.

    H-25.21 ESCROW OF CODE Q15

    For PaaS/SaaS solutions, a Cloud Services Provider (CSP) would be responsible for maintaining access in terms of performance and availability to PUC's data. PUC's data would be owned by PUC. PUC would have access to its data and metadata, but not all of the PaaS/SaaS solution source code. PUC would have full rights to extract their data at any time during the subscription service. However, PaaS/SaaS CSP does not typically offer system source code because it is inapplicable to software delivered as a service subscription through a multitenant architecture. While it is possible to provide the source code in an escrow account for a configured solution, the source code would only be able to operate in the CSP's PaaS/SaaS environment. Therefore, can PUC remove the source code requirements?

    Agreed. The escrow of code for any PaaS/SaaS solution would pertain to any customized code. This can be addressed during the contract phase.

  • Section Referencing # QUESTION ANSWERAPPENDIX C: SYSTEM REQUIREMENTS AND DELIVERABLES"The proposed solution should be able to access and update PHMSA, NFPA, PUC 500 and 800 rules..."

    Q16Can the PUC provide the specific regulations or rules that the solution will be required to comply or interface with? What are the PUC's expectations as to how these rules will be accessed and updated?

    As a rule becomes amended or updated the solutions should also be amended and updated. PHMSA rules will need to be imported and allow to be updated as they are released. Refer to the forms listed in section in Q-6. Not unlike tax preparation software, the rules need to be updated and referenced and incorporated in the solution.

    Appendix D, page 55, Topic 15 Q17

    This topic has a 6 page limit, but the questions within the topic mention the first five pages of this topic and the second five pages for this topic. Could you please clarify the desired page limit for this section?

    Agreed, Increase response page limit to 10.

    Section E-1.1.2 Q18

    As a privately held company, we do not have audited financial statements, but rather independently reviewed financial statements. These are typically considered an acceptable substitute since we are not a publicly held company. Will independently reviewed statements satisfy the requirements of Section E-1.1.2?

    Yes.

    Appendix F Q19 Appendix F states that the budget for the project shall not exceed $100,000. Does this budget include the cost of software licenses?We do anticipate the software cost to be separate from that budget item. However, we will engage the opportunity for a separate software licensing quote.

    Q20Please confirm that the Cost Proposal does not need to be submitted in a separate envelope from the technical proposal, and that both should be contained in the same binder (though different sections).

    Please see answer in Q-12.

    Q21Does PUC have a preference for integrating with the State's Active Directory or another existing LDAP?

    Due to the complexity and time limitations of this project, the PUC is not expecting (no matter how desirable) to have the hosted solution integrated with the States AD. A profile or user syncing is highly desirable.

    F1 Q22

    In Appendix F /F-1/Table F-1, the table asks for Phase One pricing, along with future Phases 2-4, is it fair to assume that the pricing for Phases 2-4 be a best guess effort since the requirements are a couple of sentences and that the vendor

    Yes.

  • Section Referencing # QUESTION ANSWER

    C-2 Q23

    For C-2 and the filling out of Attachment C-2 (General Response Checklist) how does the State want the response tables delivered?Pasted into the RFP response (many pages), printed separately and added to the RFP response (tab) original, or a copy for the original and 8 copies, or just on the CD ROM?

    Please refer to section 4.17. You would create a tab section for the response.

    C-3Q24

    "Vendors shall complete the response checklist Table C-3 Deliverables Checklist."Table C-3 Deliverables ChecklistAre we to fill out the table on pages 45 and 46 or is there an Addendum that has the table and needs to be downloaded. When I check the site I did not find a second Addendum.

    Yes. Please complete Section 3 (pages 45 and 46) with your responses. There isn't an additional addendum provided, but if there is an alternative timeline proposed then attach it as a supplemental timeline.

    Appendix C, Stage 3 Q25Stage 3 states that the Vendor will be responsible to ensure that data has been properly converted. Will the State be responsible for the cleaning/cleansing of all of its current data?

    Yes. Refer to Q-4

    F-1 Q26As a follow up to the data cleaning question, in table F1 if the vendor is responsible for the data cleaning and data migration, does the State want the cleaning also broken out in the Table sections.

    You do not need to complete a separate table for this.

    Append A Q27

    In the Project Scope it is stated that the system must provide the ability to track all inspectors location. Is the State currently using any 3rd party vehicle tracking system or personal locator system. If so what is the tool being utilized.

    No. The PUC Safety division is not using any vehicle tracking system.

    Q28 Does the public currently log complaints via the NH PUC website? How does the public log complaints.Yes. The NH PUC logs complaints from the website and via consumer services. There is no intention to connect the information to this application at this time.

    Section G Q29 Is NH PUC taking advantage of a single sign on system? If not is NH PUC open to a single sign on solution? No. This is not pertinent to this project.

    Append C Q30

    In the Project Scope, NHPUC states the field inspectors have a heavy use of photo documentation(jpegs, pdfs). What are the current document management standards for the State and NHPUC? Is the State and NH PUC open to discussing potential solutions that will enhance document management?

    Please see answer in Q-9.

  • Section Referencing # QUESTION ANSWER

    Addendum C Q31In the Requirement Document (Business Requirement), approximately 70 documents are referenced. Does the solution need to replicate all of the forms?

    Yes.

    Append H Q32 Does the code escrow requirement apply to Cloud based solutions? How would it apply to Salesforce development? Please see answer in Q-15.

    Overview (page 34) Q33 Are there currently any corporate reporting or BI tools that reports should be developed in or should they be within the platformCurrently there isn't any corporate reporting or BI tools, the solution is expected to have that ability.

    Overview (page 11) Q34 Will the calendar integration need to integrate with calendaring systems outside the proposed solution? If so, which ones? Yes. Currently we utilize an on premise Exchange environment.

    Appendix C, Section C1 (page 41) Q35

    Can labor for effort be conducted from outside US as long as systems being worked on are within the US (offshore development) Due to the sensitivity of the data, no offshore development is admissible.

    Requirements DOC H4.10 Q36

    If The Vendor is unable to meet the uptime requirement, The Vendor shall credit States account in an amount based upon the following formula: (Total Contract Item Price/365) x Number of Days Contract Item Not Provided. The State must request this credit in writing. The response that will be provided is a Cloud based system (SFDC), would SFDC be considered the Vendor and if so this requirement would need to be part of the SFDC licensing T&C and not the implementation vendor.

    If the vendor is providing the licensing, then the vendor is then responsible to ensure that this criteria is met. Otherwise, you are correct.

  • PHMSA Form 14 Question Set (IA Equivalent) PHMSA (OQ) INSPECTION FORM

    Page 1 of 4 IA v3.1.5 May 2015

    Training and Qualification - Operator Qualification

    BEC04EBE9E244A34A49B56FB9315908A-TQOQOQPLANP 1. Operator Qualification Plan and Covered Tasks (detail) Is there an OQ plan that includes covered tasks, and the basis used for identifying covered tasks? (TQ.OQ.OQPLAN.P) (detail) 192.805(a) (192.801(b)) S a t + S a t C o n c e r n U n s a t N A N C X Notes

    The operates and maintains a landfill gas (LFG) collection, conditioning and compressor system the Mt Carberry solid waste disposal facility. provides odorized LFG to the

    facility via a 6-inch dia HDPE piping system. The jurisdictional LFG piping that is owned and operated by extends approximately 10,500 feet from the outlet of the LFG processing facility to a shutoff valve adjacent to the

    M&R station.

    contracted of Pittsburg, PA to develop an Operation and Maintenance (O&M) Manual and an Emergency Response Plan as well as an Operator Qualification (OQ) Plan for the LFG pipeline system. The April 20, 2015 OQ Plan Revision 4 was reviewed as part of this inspection.

    BEC04EBE9E244A34A49B56FB9315908A-TQOQREEVALINTERVALP 2. Reevaluation Intervals for Covered Tasks (detail) Does the process establish and justify requirements for reevaluation intervals for each covered task? (TQ.OQ.REEVALINTERVAL.P) (detail) 192.805(g) S a t + S a t C o n c e r n U n s a t N A N C X Notes The plan establishes and justifies requirements for reevaluation intervals using the ENERGY worldnet system for training and evaluation.

    BEC04EBE9E244A34A49B56FB9315908A-TQOQOQPLANCONTRACTORP 3. Contractors Adhering to OQ Plan (detail) Does the process require the OQ plan to be communicated to contractors and ensure that contractors are following the plan? (TQ.OQ.OQPLANCONTRACTOR.P) (detail) 192.805(b) (192.805(f); 192.805(c)) S a t + S a t C o n c e r n U n s a t N A N C X Notes

    utilizes contractors that are qualified under the plan and contractors who provide their own qualifications as accepted under this plan. must audit a contractors existing plan prior to beginning work using the form in Section 7.2.5 if that contractor has evaluated its personnel to the provisions of that plan. It is the responsibility of the Contractor to provide qualified, competent workers under the terms of its specific contract with

    .

    BEC04EBE9E244A34A49B56FB9315908A-TQOQOQCONTRACTORP 4. Contractor and Other Entity Qualification (detail) Does the process require contractor organizations or other entities that perform covered tasks on behalf of the operator to be qualified? (TQ.OQ.OQCONTRACTOR.P) (detail) 192.805(b) (192.805(c); 192.855(d); 192.805(e); 192.805(f)) S a t + S a t C o n c e r n U n s a t N A N C X Notes The plan requires contractor organizations or other entities that perform covered tasks on behalf of the operator to be qualified.

  • PHMSA Form 14 Question Set (IA Equivalent) PHMSA (OQ) INSPECTION FORM

    Page 2 of 4 IA v3.1.5 May 2015

    BEC04EBE9E244A34A49B56FB9315908A-TQOQOQCONTRACTORR 5. Contractor and Other Entity Qualification (confirm) Are adequate records maintained for contractor personnel qualifications that contain the required elements? (TQ.OQ.OQCONTRACTOR.R) (confirm) 192.807(a) (192.807(b)) S a t + S a t C o n c e r n U n s a t N A N C X Notes Records are maintained for contractor personnel qualifications that contain the required elements.

    BEC04EBE9E244A34A49B56FB9315908A-TQOQOTHERENTITYR 6. Management of Other Entities Performing Covered Tasks (detail) Do records document evaluation of the other entity (ies) performing covered task(s) on behalf of the operator (e.g., through mutual assistance agreements) prior to performing task? (TQ.OQ.OTHERENTITY.R) (detail) 192.805(b) (192.805(c); 192.803) S a t + S a t C o n c e r n U n s a t N A N C X Notes

    is the only entity performing covered task(s) on behalf of the operator.

    BEC04EBE9E244A34A49B56FB9315908A-TQOQEVALM ETHODP 7. Evaluation Methods (detail) Are evaluation methods established and documented appropriate to each covered task? (TQ.OQ.EVALMETHOD.P) (detail) 192.805(b) (192.803; 192.809(d); 192.809(e)) S a t + S a t C o n c e r n U n s a t N A N C X Notes Evaluation methods are established and documented appropriate to each covered task

    BEC04EBE9E244A34A49B56FB9315908A-TQOQEVALM ETHODR 8. Evaluation Methods (confirm) Do records indicate evaluation methods are documented for covered tasks and consistent with personnel qualification records? (TQ.OQ.EVALMETHOD.R) (confirm) 192.805(b) (192.803; 192.809(d); 192.809(e)) S a t + S a t C o n c e r n U n s a t N A N C X Notes Records indicate evaluation methods are documented for covered tasks and consistent with personnel qualification records

    BEC04EBE9E244A34A49B56FB9315908A-TQOQABNORMALP 9. Abnormal Operating Conditions (detail) Does the process require: 1) individuals performing covered tasks be qualified to recognize and react to abnormal operating conditions (AOCs), 2) evaluation and qualification of individuals for their capability to recognize and react to AOCs, 3) AOCs identified as those that the individual may reasonably anticipate and appropriately react to during the performance of the covered task, and 4) established provisions for communicating AOCs for the purpose of qualifying individuals? (TQ.OQ.ABNORMAL.P) (detail) 192.803 S a t + S a t C o n c e r n U n s a t N A N C X Notes The Plan requires individuals performing covered tasks be qualified to recognize and react to AOCs, evaluation and qualification of individuals for their capability to recognize and react to AOCs, AOCs identified as those that the individual may reasonably anticipate and appropriately react to during the performance of the covered task, and established provisions for communicating AOCs for the purpose of qualifying individuals.

  • PHMSA Form 14 Question Set (IA Equivalent) PHMSA (OQ) INSPECTION FORM

    Page 3 of 4 IA v3.1.5 May 2015

    BEC04EBE9E244A34A49B56FB9315908A-TQOQABNORMALR 10. Abnormal Operating Conditions (detail) Do records document evaluation of qualified individuals for recognition and reaction to AOCs? (TQ.OQ.ABNORMAL.R) (detail) 192.807(a) (192.807(b); 192.803) S a t + S a t C o n c e r n U n s a t N A N C X Notes Records document the evaluation of qualified individuals for recognition and reaction to AOCs.

    BEC04EBE9E244A34A49B56FB9315908A-TQOQRECORDSR 11. Qualification Records for Personnel Performing Covered Tasks (confirm) Do records document the evaluation and qualifications of individuals performing covered tasks, and can the qualification of individuals performing covered tasks be verified? (TQ.OQ.RECORDS.R) (confirm) 192.807 S a t + S a t C o n c e r n U n s a t N A N C X Notes Records document the evaluation and qualifications of individuals performing covered tasks, and the qualification of individuals performing covered tasks were verified.

    BEC04EBE9E244A34A49B56FB9315908A-TQOQMERGERACQP 12. Planning for Mergers and Acquisitions (Due Diligence re: Acquiring Qualified Individuals) (confirm) Does the process adequately manage qualifications of individuals performing covered tasks during program integration following a merger or acquisition? (TQ.OQ.MERGERACQ.P) (confirm) 192.805(b) (192.803) S a t + S a t C o n c e r n U n s a t N A N C X Notes

    BEC04EBE9E244A34A49B56FB9315908A-TQOQTRAININGP 13. Training Requirements (Initial, Retraining, and Reevaluation) (detail) Does the OQ program provide for initial qualification, retraining and reevaluation of individuals performing covered tasks? (TQ.OQ.TRAINING.P) (detail) 192.805(h) S a t + S a t C o n c e r n U n s a t N A N C X Notes The program provide for initial qualification, retraining and reevaluation of individuals performing covered tasks.

    BEC04EBE9E244A34A49B56FB9315908A-TQOQNONQUALIFIEDP 14. Covered Task Performed by Non-Qualified Individual (confirm) Are there provisions for non-qualified individuals to perform covered tasks while being directed and observed by a qualified individual, and are there restrictions and limitations placed on such activities? (TQ.OQ.NONQUALIFIED.P) (confirm) 192.805(c) S a t + S a t C o n c e r n U n s a t N A N C X Notes There are provisions for non-qualified individuals to perform covered tasks while being directed and observed by a qualified individual, and restrictions and limitations placed on such activities.

  • PHMSA Form 14 Question Set (IA Equivalent) PHMSA (OQ) INSPECTION FORM

    Page 4 of 4 IA v3.1.5 May 2015

    BEC04EBE9E244A34A49B56FB9315908A-TQOQPERFMONITORP 15. Personnel Performance Monitoring (detail) Does the program include provisions to evaluate an individual if there is reason to believe the individual is no longer qualified to perform a covered task based on: covered task performance by an individual contributed to an incident or accident; other factors affecting the performance of covered tasks? (TQ.OQ.PERFMONITOR.P) (detail) 192.805(d) (192.805(e)) S a t + S a t C o n c e r n U n s a t N A N C X Notes The program includes provisions to evaluate an individual if there is reason to believe the individual is no longer qualified to perform a covered task .

    BEC04EBE9E244A34A49B56FB9315908A-TQOQMOCP 16. Management of Changes (confirm) Does the OQ program identify how changes to procedures, tools standards and other elements used by individuals in performing covered tasks are communicated to the individuals, including contractor individuals, and how these changes are implemented in the evaluation method(s)? (TQ.OQ.MOC.P) (confirm) 192.805(f) S a t + S a t C o n c e r n U n s a t N A N C X Notes The program identifies how changes to procedures, tools standards and other elements used by individuals in performing covered tasks are communicated to the individuals, including contractor individuals, and how these changes are implemented in the evaluation method.

    BEC04EBE9E244A34A49B56FB9315908A-TQOQCHANGENOTIFYP 17. Notification of Significant Plan Changes (confirm) Does the process require significant OQ program changes to be identified and the Administrator or State agency notified? (TQ.OQ.CHANGENOTIFY.P) (confirm) 192.805(i) S a t + S a t C o n c e r n U n s a t N A N C X Notes The process requires significant OQ program changes be identified and the Administrator or State agency be notified.

    Acceptable Use: Inspection documentation, including completed protocol forms, summary reports, executive summary reports, and enforcement documentation are for internal use only by federal or state pipeline safety regulators. Some inspection documentation may contain information which the operator considers to be confidential. In addition, supplemental inspection guidance and related documents in the file library are also for internal use only by federal or state pipeline safety regulators (with the exception of documents published in the federal register, such as advisory bulletins). Do not distribute or otherwise disclose such material outside of the state or federal pipeline regulatory organizations. Requests for such information from other government organizations (including, but not limited to, NTSB, GAO, IG, or Congressional Staff) should be referred to PHMSA Headquarters Management.

    Training and Qualification - Operator Qualification
  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    PHMSA Form 14 Page 1 of 1

    INSPECTOR

    David Burnell __X _ Randy Knepper ____ Joe Vercellotti _X___

    OPERATOR Liberty Utilities ____ Unitil ____ Liberty (Keene) ____

    Androscoggin Valley Regional Refuse Disposal District (AVRRDD) ____

    Gorham Paper & Tissue (GP&T) _X___ UNH ____ Other _____

    INSPECTION UNIT

    Liberty (N) ____ Liberty (C) ____ Liberty (S) ____ NU Portsmouth ____ Liberty (Keene) ____

    LNG (Concord) ____ LNG (Manchester) ____ (LNG) Tilton ____

    Androscoggin Valley Regional Refuse Disposal District (AVRRDD) ____

    Gorham Paper & Tissue (GP&T) __X__ UNH ____ Other _____ OPERATOR TYPE Distribution

    LP Air Plant: Nashua ____ Manchester ____ Tilton ____

    Master Meter ____ Private ____ LP Gas ____ LNG Plant ____ (UNH)

    Transmission (Intrastate)_X___ Transmission (Interstate)____ (GP&T, AVRRDD, UNH Eco-line) (Integrity Management) (TGP, GSGT, PNGT, M & N) INSPECTION TYPE Note: Please indicate sequence # to be referenced in database i.e. 1, 2, 3, etc.

    O&M Standard __1 __ Design-Testing-Construction ____ On-Site Operator Training ____ (Standard Comprehensive) (Field)

    Integrity Management ____ OQ _2___ Investigating Incidents/Accidents ____

    Dig Safe ____ Compliance Follow-up ____ Drug & Alcohol ____ (Damage Prevention) (NOTE: Drug & Alcohol must always be marked O & M Standard #1 and Drug & Alcohol #2) INSPECTION DATE 02/18/2016

    INSPECTION MODULE PHMSA Form 14

    CODE REFERENCE 192.801(b),192.803,192.803,192.803,192.803,192.803,192.803,192.805(a),192.805(b),192.805(b),192.805(b),192.805(b),192.805(b),192.805(b),192.805(c),192.805(c),192.805(c),192.805(c),192.805(d),192.805(e),192.805(e),192.805(f),192.805(f),192.805(f),192.805(g),192.805(h),192.805(i),192.807,192.807(a),192.807(a),192.807(b),192.807(b),192.809(d),192.809(d),192.809(e),192.809(e), 192.855(d)

    PERSON DAYS 1.0 __X ____ 0.5 __ ____

    PLANS REVIEWED O&M ____ Emergency Plan ____ Damage Prevention ____ OQ _X___ IMP _____

    OPERATOR PERSONNEL PRESENT

    DOCUMENTS PROVIDED TO OPERATOR Yes _______ No __X_____ Type:

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    PHMSA Form 14 Page 2 of 2

    Provide description of observations and note probable violations where applicable RSK Review Date:

    Notes: Reference the OQ PHMSA Form 14 on file

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 1

    INSPECTOR

    David Burnell ______ Joseph Vercellotti ___X____ Randy Knepper ______

    OPERATOR Liberty Utilities _X___ Unitil ____ NH Gas ____

    Androscoggin Valley Regional Refuse Disposal District (AVRRDD) ____ Gorham Paper & Tissue (GP&T) ____

    Beech Hill Apt ____ Dover Housing ____ UNH ____ Other ________________

    INSPECTION UNIT Liberty Utilities (N) ___ Liberty Utilities (C) _X_ Liberty Utilities (S) _X__ NU Portsmouth ____ NH Gas ____

    LNG (Concord) ____ LNG (Manchester) ____ (LNG) Tilton ____

    Androscoggin Valley Regional Refuse Disposal District (AVRRDD) ____ Gorham Paper & Tissue (GP&T) ____

    Beech Hill Apt ____ Dover Housing ____ UNH ____ Other ________________

    OPERATOR TYPE Distribution

    LP Air Plant: Nashua ___ Manchester ___ Tilton ___ (Liberty)

    Master Meter ____ Private _X__ LP Gas ____ LNG Plant ____ (Dover Housing, Beech Hill, UNH)

    Transmission (Intrastate)____ Transmission (Interstate)____ (GP&T, AVRRDD, UNH Eco-line) (Integrity Management) (TGP, GSGT, PNGT, M & N) INSPECTION TYPE Note: Please indicate sequence # to be referenced in database i.e. 1, 2, 3, etc.

    O&M Standard _X___ Design-Testing-Construction ____ On-Site Operator Training ____ (Standard Comprehensive) (Field)

    Integrity Management ____ OQ ____ Investigating Incidents/Accidents ____

    Dig Safe ____ Compliance Follow-up ____ Drug & Alcohol ____ (Damage Prevention) (NOTE: Drug & Alcohol must always be marked O & M Standard #1 and Drug & Alcohol #2) INSPECTION DATE 05-08-2014 INSPECTION MODULE CODE REFERENCE 192.59, 192.63, 192.281, 192.283, 192.285, 192.287, 192.321, 192.325, 192.327, 192.225, 192.235,

    192.509 PERSON DAYS 1.0 _X__ 0.5 ____ PLANS REVIEWED O&M ____ Emergency Plan ____ Damage Prevention ____ OQ ____ IMP _____ OPERATOR PERSONNEL PRESENT DOCUMENTS PROVIDED TO OPERATOR Yes ____ No _X___ Type:

    Provide description of observations and note probable violations where applicable RSK Review Date:

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 2

    Notes:

    1. On behalf of Liberty, was installing approximately 120 linear feet of 6-inch dia medium density polyethylene (MDPE) piping along the southern edge of Merrimack St. in the vicinity of Union St. in Manchester. The pipe was being installed as part of a cast iron pipe replacement project. The 6-inch dia pipe consisted of DR11.5 Driscoplex 6500 PE2406/2708 MDPE which had a manufacture date of 05/19/13. The MDPE main and underlying tracerwire were bedded in sand at an approximate depth of 36-inches below grade. Sections of pipe were joined above grade using a butt-welding machine. The section of main was joined to the main in the trench using an electro fusion coupling.

    2. On behalf of Liberty, was welding a section of 6-inch diameter steel main to a new valve on the east side of a railroad crossing at the Broad Street Parkway in Nashua. The Kerotest EV-11 6-inch valve was welded to the main consistent with Liberty O&M Welding Policy PL-30020 and welding procedure SMAW 7018. RH White pressure tested a stopper tee that was previously welded to the main at 90 psi for a one hour period.

    Code Reference: 192.59 (a) New plastic pipe is qualified for use under this part if: (1) It is manufactured in accordance with a listed specification; and (2) It is resistant to chemicals with which contact may be anticipated. (b) Used plastic pipe is qualified for use under this part if: (1) It was manufactured in accordance with a listed specification; (2) It is resistant to chemicals with which contact may be anticipated; (3) It has been used only in natural gas service. (4) Its dimensions are still within the tolerances of the specification to which it was manufactured; and, (5) It is free of visible defects. (c) For the purpose of paragraphs (a)(1) and (b)(1) of this section, where pipe of a diameter included in a listed specification is impractical to use, pipe of a diameter between the sizes included in a listed specification may be used if it: (1) Meets the strength and design criteria required of pipe included in that listed specification; and (2) Is manufactured from plastic compounds which meet the criteria for material required of pipe included in that listed specification. 192.63 (a) Except as provided in paragraph (d) of this section, each valve, fitting, length of pipe, and other component must be marked-- (1) As prescribed in the specification or standard to which it was manufactured, except that thermoplastic fittings must be marked in accordance with ASTM D2513-87 (incorporated by reference, see 192.7); (2) To indicate size, material, manufacturer, pressure rating, and temperature rating, and as appropriate, type, grade, and model. (b) Surfaces of pipe and components that are subject to stress from internal pressure may not be field die stamped. (c) If any item is marked by die stamping, the die must have blunt or rounded edges that will minimize stress concentrations. (d) Paragraph (a) of this section does not apply to items manufactured before November 12, 1970, that meet all of the following: (1) The item is identifiable as to type, manufacturer, and model. (2) Specifications or standards giving pressure, temperature, and other appropriate criteria for the use of items are readily available. 192.281 (a) General. A plastic pipe joint that is joined by solvent cement, adhesive, or heat fusion may not be disturbed until it has properly set. Plastic pipe may not be joined by a threaded joint or miter joint. (b) Solvent cement joints. Each solvent cement joint on plastic pipe must comply with the following: (1) The mating surfaces of the joint must be clean, dry, and free of material which might be detrimental to the joint.

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 3

    (2) The solvent cement must conform to ASTM D2513-99, (incorporated by reference, see 192.7). (3) The joint may not be heated to accelerate the setting of the cement. (c) Heat-fusion joints. Each heat-fusion joint on plastic pipe must comply with the following: (1) A butt heat-fusion joint must be joined by a device that holds the heater element square to the ends of the piping, compresses the heated ends together, and holds the pipe in proper alignment while the plastic hardens. (2) A socket heat-fusion joint must be joined by a device that heats the mating surfaces of the joint uniformly and simultaneously to essentially the same temperature. (3) An electrofusion joint must be joined utilizing the equipment and techniques of the fittings manufacturer or equipment and techniques shown, by testing joints to the requirements of 192.283(a)(1)(iii), to be at least equivalent to those of the fittings manufacturer. 4) Heat may not be applied with a torch or other open flame. (d) Adhesive joints. Each adhesive joint on plastic pipe must comply with the following: (1) The adhesive must conform to ASTM /ANSI Designation: D 2517. (2) The materials and adhesive must be compatible with each other. (e) Mechanical joints. Each compression type mechanical joint on plastic pipe must comply with the following: (1) The gasket material in the coupling must be compatible with the plastic. (2) A rigid internal tubular stiffener, other than a split tubular stiffener, must be used in conjunction with the coupling. 192.283 (a) Heat fusion, solvent cement, and adhesive joints. Before any written procedure established under 192.273(b) is used for making plastic pipe joints by a heat fusion, solvent cement, or adhesive method, the procedure must be qualified by subjecting specimen joints made according to the procedure to the following tests: (1) The burst test requirements of-- (i) In the case of thermoplastic pipe, paragraph 6.6 (sustained pressure test) or paragraph 6.7 (Minimum Hydrostatic Burst Test) or paragraph 8.9 (Sustained Static pressure Test) of ASTM D2513-99 (incorporated by reference, see 192.7); (ii) In the case of thermosetting plastic pipe, paragraph 8.5 (Minimum Hydrostatic Burst Pressure) or paragraph 8.9 (Sustained Static Pressure Test) of ASTM D2517 (incorporated by reference, see 192.7); or (iii) In the case of electrofusion fittings for polyethylene (PE) pipe and tubing, paragraph 9.1 (Minimum Hydraulic Burst Pressure Test), paragraph 9.2 (Sustained Pressure Test), paragraph 9.3 (Tensile Strength Test), or paragraph 9.4 (Joint Integrity Tests) of ASTM Designation F1055 (incorporated by reference, see 192.7). (2) For procedures intended for lateral pipe connections, subject a specimen joint made from pipe sections joined at right angles according to the procedure to a force on the lateral pipe until failure occurs in the specimen. If failure initiates outside the joint area, the procedure qualifies for use; and (3) For procedures intended for non-lateral pipe connections, follow the tensile test requirements of ASTM D638 (incorporated by reference, see 192.7), except that the test may be conducted at ambient temperature and humidity If the specimen elongates no less than 25 percent or failure initiates outside the joint area, the procedure qualifies for use. (b) Mechanical joints. Before any written procedure established under 192.273(b) is used for making mechanical plastic pipe joints that are designed to withstand tensile forces, the procedure must be qualified by subjecting five specimen joints made according to the procedure to the following tensile test: (1) Use an apparatus for the test as specified in ASTM D 638 (except for conditioning), (incorporated by reference, see 192.7). (2) The specimen must be of such length that the distance between the grips of the apparatus and the end of the stiffener does not affect the joint strength. (3) The speed of testing is 0.20 in. (5.0 mm) per minute, plus or minus 25 percent. (4) Pipe specimens less than 4 inches (102 mm) in diameter are qualified if the pipe yields to an elongation of no less than 25 percent or failure initiates outside the joint area.

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 4

    (5) Pipe specimens 4 inches (102 mm) and larger in diameter shall be pulled until the pipe is subjected to a tensile stress equal to or greater than the maximum thermal stress that would be produced by a temperature change of 100F (38C) or until the pipe is pulled from the fitting. If the pipe pulls from the fitting, the lowest value of the five test results or the manufacturer's rating, whichever is lower must be used in the design calculations for stress. (6) Each specimen that fails at the grips must be retested using new pipe. (7) Results obtained pertain only to the specific outside diameter, and material of the pipe tested, except that testing of a heavier wall pipe may be used to qualify pipe of the same material but with a lesser wall thickness. (c) A copy of each written procedure being used for joining plastic pipe must be available to the persons making and inspecting joints. (d) Pipe or fittings manufactured before July 1, 1980, may be used in accordance with procedures that the manufacturer certifies will produce a joint as strong as the pipe. 192.285 (a) No person may make a plastic pipe joint unless that person has been qualified under the applicable joining procedure by: (1) Appropriate training or experience in the use of the procedure; and (2) Making a specimen joint from pipe sections joined according to the procedure that passes the inspection and test set forth in paragraph (b) of this section. (b) The specimen joint must be: (1) Visually examined during and after assembly or joining and found to have the same appearance as a joint or photographs of a joint that is acceptable under the procedure; and (2) In the case of a heat fusion, solvent cement, or adhesive joint; (i) Tested under any one of the test methods listed under 192.283(a) applicable to the type of joint and material being tested; (ii) Examined by ultrasonic inspection and found not to contain flaws that would cause failure; or (iii) Cut into at least three longitudinal straps, each of which is: (A) Visually examined and found not to contain voids or discontinuities on the cut surfaces of the joint area; and (B) Deformed by bending, torque, or impact, and if failure occurs, it must not initiate in the joint area. (c) A person must be requalified under an applicable procedure, if during any 12-month period that person: (1) Does not make any joints under that procedure; or (2) Has 3 joints or 3 percent of the joints made, whichever is greater, under that procedure that are found unacceptable by testing under 192.513. (d) Each operator shall establish a method to determine that each person making joints in plastic pipelines in the operator's system is qualified in accordance with this section. 192.287 No person may carry out the inspection of joints in plastic pipes required by 192.273(c) and 192.285(b) unless that person has been qualified by appropriate training or experience in evaluating the acceptability of plastic pipe joints made under the applicable joining procedure. 192.321 (a) Plastic pipe must be installed below ground level except as provided by paragraphs (g) and (h) of this section. (b) Plastic pipe that is installed in a vault or any other below grade enclosure must be completely encased in gas-tight metal pipe and fittings that are adequately protected from corrosion. (c) Plastic pipe must be installed so as to minimize shear or tensile stresses. (d) Thermoplastic pipe that is not encased must have a minimum wall thickness of 0.090 inch (2.29 millimeters), except that pipe with an outside diameter of 0.875 inch (22.3 millimeters) or less may have a minimum wall thickness of 0.062 inch(1.58 millimeters). (e) Plastic pipe that is not encased must have an electrically conducting wire or other means of locating the pipe while it is underground. Tracer wire may not be wrapped around the pipe and contact with the pipe must be minimized but is not prohibited. Tracer wire or other metallic elements installed for pipe locating purposes must be resistant to corrosion

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 5

    damage, either by use of coated copper wire or by other means. (f) Plastic pipe that is being encased must be inserted into the casing pipe in a manner that will protect the plastic. The leading end of the plastic must be closed before insertion. (g) Uncased Plastic pipe may be temporarily installed above ground level under the following conditions: (1) The operator must be able to demonstrate that the cumulative aboveground exposure of the pipe does not exceed the manufacturer's recommended maximum period of exposure or 2 years, whichever is less. (2) The pipe either is located where damage by external forces is unlikely or is otherwise protected against such damage. (3) The pipe adequately resists exposure to ultraviolet light and high and low temperatures. (h) Plastic pipe may be installed on bridges provided that it is: (1) Installed with protection from mechanical damage, such as installation in a metallic casing; (2) Protected from ultraviolet radiation; and (3) Not allowed to exceed the pipe temperature limits specified in 192.123. 192.325 (a) Each transmission line must be installed with at least 12 inches (305 millimeters) of clearance from any other underground structure not associated with the transmission line. If this clearance cannot be attained, the transmission line must be protected from damage that might result from the proximity of the other structure. (b) Each main must be installed with enough clearance from any other underground structure to allow proper maintenance and to protect against damage that might result from proximity to other structures. (c) In addition to meeting the requirements of paragraphs (a) or (b) of this section, each plastic transmission line or main must be installed with sufficient clearance, or must be insulated, from any source of heat so as to prevent the heat from impairing the serviceability of the pipe. (d) Each pipe-type or bottle-type holder must be installed with a minimum clearance from any other holder as prescribed in 192.175(b). 192.327 (b) Except as provided in paragraphs (c) and (d) of this section, each buried main must be installed with at least 24 inches (610 millimeters) of cover. (c) Where an underground structure prevents the installation of a transmission line or main with the minimum cover, the transmission line or main may be installed with less cover if it is provided with additional protection to withstand anticipated external loads. (d) A main may be installed with less than 24 inches (610 millimeters) of cover if the law of the State or municipality: (1) Establishes a minimum cover of less than 24 inches (610 millimeters); (2) Requires that mains be installed in a common trench with other utility lines; and, (3) Provides adequately for prevention of damage to the pipe by external forces. (e) Except as provided in paragraph (c) of this section, all pipe installed in a navigable river, stream, or harbor must be installed with a minimum cover of 48 inches (1,219 millimeters) in soil or 24 inches (610 millimeters) in consolidated rock between the top of the pipe and the underwater natural bottom (as determined by recognized and generally accepted practices). (f) All pipe installed offshore, except in the Gulf of Mexico and its inlets, under water not more than 200 feet (60 meters) deep, as measured from the mean low tide, must be installed as follows: (1) Except as provided in paragraph (c) of this section, pipe under water less than 12 feet (3.66 meters) deep, must be installed with a minimum cover of 36 inches (914 millimeters) in soil or 18 inches (457 millimeters) in consolidated rock between the top of the pipe and the natural bottom. (2) Pipe under water at least 12 feet (3.66 meters) deep must be installed so that the top of the pipe is below the natural bottom, unless the pipe is supported by stanchions, held in place by anchors or heavy concrete coating, or protected by an equivalent means. (g) All pipelines installed under water in the Gulf of Mexico and its inlets, as defined in 192.3, must be installed in accordance with 192.612(b)(3). 192.225 (a) Welding must be performed by a qualified welder in accordance with welding procedures qualified under section 5 of API 1104 (incorporated by reference, see 192.7) or section IX of the ASME Boiler and Pressure Vessel Code

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 6

    " Welding and Brazing Qualifications" (incorporated by reference, see 192.7) to produce welds meeting the requirements of this subpart. The quality of the test welds used to qualify welding procedures shall be determined by destructive testing in accordance with the applicable welding standard(s). (b) Each welding procedure must be recorded in detail, including the results of the qualifying tests. This record must be retained and followed whenever the procedure is used. 192.235 Before beginning any welding, the welding surfaces must be clean and free of any material that may be detrimental to the weld, and the pipe or component must be aligned to provide the most favorable condition for depositing the root bead. This alignment must be preserved while the root bead is being deposited. 192.509 Except for service lines and plastic pipelines, each segment of a pipeline that is to be operated below 100 psi (680 kPa) gage must be leak tested in accordance with the following: (a) The test procedure used must ensure discovery of all potentially hazardous leaks in the segment being tested. (b) Each main that is to be operated at less than 1 psi (6.9 kPa) gage must be tested to at least 10 psi (69 kPa) gage and each main to be operated at or above 1 psig must be tested to at least 90 psi (621 kPa) gage.

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 7

    05-08-2014 Liberty Merrimack St, Manchester

    was installing approximately 120 linear feet of 6-inch dia medium density polyethylene (MDPE) piping along the southern edge of Merrimack St. in the vicinity of Union St. in Manchester. The pipe was being installed as part of a cast iron pipe replacement project.

    05-08-2014 Liberty Merrimack St, Manchester

    Sections of pipe were joined above grade using a butt-welding machine. The pipe sections appeared to have proper alignment and the 1/8-inch weld bead appeared to be uniform.

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 8

    05-08-2014 Broad Street Parkway, Nashua

    was welding a section of 6-inch diameter steel main to a new valve on the east side of a railroad crossing at the Broad Street Parkway in Nashua. The Kerotest EV-11 6-inch valve was welded to the main consistent with Liberty O&M Welding Policy PL-30020 and welding procedure SMAW 7018.

    05-08-2014 Broad Street Parkway, Nashua

    pressure tested a stopper tee that was previously welded to the main at 90 psi for a one hour period.

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 1

    INSPECTOR

    David Burnell ___X___ Joseph Vercellotti __X_____ Randy Knepper _X_____

    OPERATOR Liberty Utilities _X___ Unitil ____ NH Gas ____

    Androscoggin Valley Regional Refuse Disposal District (AVRRDD) ____ Gorham Paper & Tissue (GP&T) ____

    Beech Hill Apt ____ Dover Housing ____ UNH ____ Other ________________

    INSPECTION UNIT Liberty Utilities (N) _X__ Liberty Utilities (C) _X__ Liberty Utilities (S) X__ NU Portsmouth ____ NH Gas ____

    LNG (Concord) ____ LNG (Manchester) ____ (LNG) Tilton ____

    Androscoggin Valley Regional Refuse Disposal District (AVRRDD) ____ Gorham Paper & Tissue (GP&T) ____

    Beech Hill Apt ____ Dover Housing ____ UNH ____ Other ________________

    OPERATOR TYPE Distribution

    LP Air Plant: Nashua ___ Manchester ___ Tilton ___ (Natl Grid)

    Master Meter ____ Private _X__ LP Gas ____ LNG Plant ____ (Dover Housing, Beech Hill, UNH)

    Transmission (Intrastate)____ Transmission (Interstate)____ (GP&T, AVRRDD, UNH Eco-line) (Integrity Management) (TGP, GSGT, PNGT, M & N) INSPECTION TYPE Note: Please indicate sequence # to be referenced in database i.e. 1, 2, 3, etc.

    O&M Standard ____ Design-Testing-Construction ____ On-Site Operator Training ____ (Standard Comprehensive) (Field)

    Integrity Management ____ OQ _X___ Investigating Incidents/Accidents ____

    Dig Safe ____ Compliance Follow-up ____ Drug & Alcohol ____ (Damage Prevention) (NOTE: Drug & Alcohol must always be marked O & M Standard #1 and Drug & Alcohol #2) INSPECTION DATE 09-11-2014 INSPECTION MODULE OQ CODE REFERENCE 192.801, 192.803, 192.805, 192.807 and 192.809 PERSON DAYS 1.0 _X___ 0.5 ____ PLANS REVIEWED O&M ____ Emergency Plan ____ Damage Prevention ____ OQ __X__ IMP _____ OPERATOR PERSONNEL PRESENT DOCUMENTS PROVIDED TO OPERATOR Yes ____ No __X__ Type:

    Provide description of observations and note probable violations where applicable RSK Review Date:

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 2

    Notes: NHPUC met with Liberty to review the OQ Plan which was updated on 8/7/2014. The OQ Plan includes 83 covered tasks and a description of the basis used for identifying covered tasks. The last OQ inspection was conducted during October 2005. PHMSA requires a 5-year plan review cycle. NHPUC met with Liberty to continue the review the OQ Plan which was updated on 8/7/2014. The inspection was conducted on 09-11-2014, 10-03-2014 and 11-21-2014. The following inspection notes were used to supplement the OQ Plan inspection observations summarized the attached PHMSA OQ Inspection Form 14. Liberty currently has five outside contractors that operate under the NGA plan. How are contractors aware of the task specific AOCs? are the outside contractors currently used by Liberty. subs under . Liberty is transitioning the OQ data base to the ITS database. Training modules are developed for every covered task. Liberty supplements the training modules with power points, testing and hands on training. There is a 2-day gap between training and testing. The Liberty employee testing is completed online in ATs office. The outside contractors are tested and proctored by NGA. Outside welder OQs are listed under . welds for . Are there Liberty covered tasks that are not considered by NGA? No. Pigging is not listed as a covered task. Where does that fall under in the OQ training? Task 31 Pipe Installation? A training power point for Task 31 was reviewed. The power point was a National Grid presentation which did not include pigging. AT indicated the tests do not cover every field activity. An example of on-line training modules (measuring pipe to soil CP potential) was presented. The module was developed by ITS. The training for outside contractors currently appears to lack the additional AOCs identified by Liberty. GC covers the additional AOCs with outside contractors when they are initially brought in. Currently Contractors are updated with the AOCs on an ad hoc basis. In the future during the Contractors annual refresher training Liberty will cover additional OQ AOCs. GC has class list of Contractor workers that have attended the training. A smartphone scan will likely be available in 2015 to obtain workers OQ information in the field. There is not a difference in the qualification cards for Liberty employees and NGA cards issued for outside contractors. Liberty does not have personnel qualified to complete plastic butt-fusions. How are the contractors qualified under the Liberty OQ plan? Through additional training provided by Liberty. The Liberty training of AOCs is not reflected on the current training cards carried by Contractors. GC forwarded the Liberty training lists for outside contractors. AT tracks OQ qualification intervals using the Energy World Net notification process. When requalification is required the test is downloaded from Energy World Net and the test is administered by Liberty. Appendix E, Section 6 and Section 7 do not allow for non-qualified individuals to perform covered tasks under direct supervision of a qualified individual. Liberty will correct this to reflect the NGA requirement in section 3.3. Damage Prevention covered task 21. Is the OQ training considered to qualify individuals to locate utilities consistent with Puc 804.03 requirements? Liberty indicated that analysis has not been completed. The Puc 800 rules will expire in 2016. Task 31 Installation of a pipe was reviewed. The Appendix G Section 8 AOCs to recognize and react for Task 31 appeared to be grouped improperly. Liberty indicated the groupings will be reviewed and revised accordingly. OQ Plan Appendix E, Section 1 - Responsibilities Executive Sponsor OQ Plan Owner OQ Administrator Director of Gas Operations Supervisors of Gas Operations Manager of Procurement Inventory Control

  • New Hampshire Public Utilities Commission Gas Safety Field Inspection Report

    Revised 7/16/2012

    Page 3

    Is there a separate training data base outside of OQ? A data base for Liberty employees is maintained. An annual meeting is held with contractors to update them with O&M and OQ changes. OQ for propane air plants is included in this plan. OQ for LNG plants is outside of this plan. Under the plan the AOCs for Task 70 and 70P are the same. Liberty is unsure whether these should be tested the same? No Appendix E, Section 3 Liberty needs to adjust the language to verify the training and drug testing of outside contractors. Appendix E, Section 3.3 - Evaluation Methods Liberty will remove work history The OQ Plan has domains and elements for only a select few tasks. An NGA committee is still working to finish up developing domains and elements for the remaining tasks. An alternative may be for Liberty to go ahead and develop those domains and elements. was taken aback regarding the criticism of the plan. Does the plan distinguish between transmission and distribution requirements? OQ covered tasks 25, 26, and 27 identify tasks specific to work on transmission lines. The task 27 training module was presented. Differences between the Liberty and NGA plan are summarized in Appendix F. Recent changes in Appendix H and Appendix I which were noted in the Section 6.0 revision history. The plan does not specifically identify how changes to procedures, tools standards and other elements used by individuals in performing covered tasks are communicated to the individuals, including contractor individuals, and how changes are implemented in the evaluation method. The NGA portion of the Plan in Section 11.0 does not specifically describe how changes to covered tasks will be communicated to Liberty staff and contractors.

    OPS Form 3.1.10 Word Alcohol Misuse Audit Protocol H- N CVR LTR Rev 10.2016.doc

    New Hampshire Public Utilities Commission

    Gas Safety Field Inspection Report

    INSPECTOR

    David Burnell ____ Randy Knepper ____ Joe Vercellotti ____

    OPERATOR

    Liberty Utilities ____ Unitil ____ Liberty (Keene) ____

    Androscoggin Valley Regional Refuse Disposal District (AVRRDD) ____

    Gorham Paper & Tissue (GP&T) ____ UNH ____ Other ____

    INSPECTION UNIT

    Liberty (N) ____ Liberty (C) ____ Liberty (S) ____ NU Portsmouth ____ Liberty (Keene) ____

    LNG (Concord) ____ LNG (Manchester) ____ (LNG) Tilton ____

    Androscoggin Valley Regional Refuse Disposal District (AVRRDD) ____

    Gorham Paper & Tissue (GP&T) ____ UNH ____ Other ____

    OPERATOR TYPE

    Distribution

    LP Air Plant: Nashua ____ Manchester ____ Tilton ____

    Master Meter ____ Private ____ LP Gas ____LNG Plant ____

    (UNH)

    Transmission (Intrastate)____ Transmission (Interstate)____

    (GP&T, AVRRDD, UNH Eco-line) (Integrity Management) (TGP, GSGT, PNGT, M & N)

    INSPECTION TYPE

    Note: Please indicate sequence # to be referenced in database i.e. 1, 2, 3, etc.

    O&M Standard ____ Design-Testing-Construction ____ On-Site Operator Training ____

    (Standard Comprehensive) (Field)

    Integrity Management ____ OQ ____ Investigating Incidents/Accidents ____

    Dig Safe ____ Compliance Follow-up ____ Drug & Alcohol ____

    (Damage Prevention) (NOTE: Drug & Alcohol must always be marked

    O & M Standard #1 and Drug & Alcohol #2)

    INSPECTION DATE

    INSPECTION MODULE OPS Form 3.1.10 Alcohol Misuse Audit Protocol H- N

    CODE REFERENCE

    199.1, 199.117(b), 199.119(a), 199.119(f), 199.202, 199.209(b)(1), 199.209(b)(2), 199.209(b)(3), 199.215, 199.217, 199.219, 199.221, 199.223, 199.225(a)(1), 199.225(a)(2), 199.225(b), 199.225(b)(2), 199.225(b)(3), 199.225(b)(4)(i), 199.225(c), 199.225(d), 199.227(a), 199.227(b)(1), 199.229(a), 199.229(d), 199.231(b), 199.233, 199.235, 199.237(a), 199.239(a), 199.239(a)(1), 199.239(a)(2), 199.239(b), 199.241, 199.243, 199.243(a), 199.243(b), 199.243(c), 199.243(c)(2)(ii), 199.245, 199.245(c), 40.333(a)(3), 40.333(a)(2), 40.333(a)(1), 40.13, 40.229, 40.23(c), 40.231, 40.233, 40.25(a), 40.25(b), 40.26, 40.285, 40.285(a), 40.285(b), 40.289(b), 40.305(a), 40.307, 40.307(a), 40.309, 40.333(c), 40.341, 40.409(b)

    PERSON DAYS 1.0 ______ 0.5 ______

    PLANS REVIEWED O&M ____ Emergency Plan ____ Damage Prevention ____ OQ ____ IMP _____

    OPERATOR PERSONNEL PRESENT

    DOCUMENTS PROVIDED TO OPERATOR Yes _______ No _______

    Type:

    Provide description of observations and note probable violations where applicable

    RSK Review Date:

    Notes:

    PAGE

    PHMSA FORM 3.1.10Page 2 of 2

    OPS Form 3.1.10 Word Alcohol Misuse Audit Protocol H- N.doc

    Pipeline and Hazardous Materials Safety Administration

    Office of Pipeline Safety

    Substance Abuse Program:

    Comprehensive Audit and Inspection Protocol Form

    Alcohol Misuse Programs

    Form No.: 3.1.10

    Revision 1

    June 1, 2012

    Replaces and Provides Comprehensive

    Anti-Drug Program and Alcohol Misuse Program

    HQ Inspection Forms

    Operator/Contractor Profile and General Audit Information

    Company :

    Name:

    Mailing and Official Address (If different):

    Doing Business As or Affiliation:

    PHMSA Operator Identification (OpID) No. or Contractor Business Tax ID No. (BTIN)

    Other OpID or BTIN Nos. covered by the above operators or contractors Substance Abuse Plan:

    Companys DER or Substance Abuse Program Mgr:

    Name and Title:

    Phone No.:

    Mailing Address:

    Email Address:

    Consortium or Third Party Administrator (C/TPA )

    C/TPA Point of Contact

    Company

    Name:

    Contact Name:

    Ph. No.:

    Ph. No.:

    Fax No.:

    Fax No.:

    Web Site or Email

    Email

    Address:

    Lead Auditor or Inspector

    Name:

    Agency:

    Date of Audit or Inspection:

    Total number employees performing covered functions (as defined in 199.3) who are under this Substance Abuse Plan, including those within OpID Nos or BTIN Nos. listed above. Refer to the operators most recent Management Information System (MIS) or statistical drug and alcohol testing report, if available. If not available at time of the audit, have the operator provide this information to the inspector or email to: [email protected] within 30 days of the request.

    Total number of operators employees (included those within OpID Nos. or BTIN Nos listed above).

    Company Representatives Participating

    Key Persons

    Name/Title/Mailing Address

    Phone/Email Address

    Primary Operator or Contractor Representative Interviewed or Providing Information

    Others Interviewed, Providing Information or Present at Audit or Inspection:

    Government or Other Official Representatives Participating:

    Name/Title

    Office/Organization

    Phone/Email Address

    Type of Facility:

    (Operators only Check-off all that apply)

    Gas Distribution Pipeline

    Transport Hazardous Liquid Pipeline

    Gas Transmission Pipeline

    Transport Carbon Dioxide Pipeline

    Gas Gathering Pipeline

    Liquefied Natural Gas Pipeline Facility

    Other: Transportation identified as:

    Plan and Policy Developed by:

    Testing Program Administered by:

    (Check-off all that apply)

    (Check-off all that apply)

    Drug

    Alcohol

    Drug

    Alcohol

    Operator

    Operator

    Contractor

    Contractor

    TPA

    TPA

    Consortium

    Consortium

    Consultant

    Consultant

    Other:

    Other:

    Contractor Records Maintained by:

    Specimen Collection Conducted by:

    (Check-off all that apply)

    (Check-off all that apply)

    Drug

    Alcohol

    Drug

    Alcohol

    Operator

    Operator Personnel On-Site

    Contractor

    Operator Personnel Off-Site

    TPA

    Contractor Personnel On-Site

    Consortium

    Contractor Personnel Off-Site

    Consultant

    Third Party Collector On-Site

    Other:

    Third Party Collector Off-Site

    MIS Reports Submitted to:

    Additional Statistical Testing Reports Submitted to:

    (Check-off all that apply)

    (Check-off all that apply and identify entity by name-Use notes page for additional entity names)

    Drug

    Alcohol

    Drug

    Alcohol

    Name

    FAA

    Operator:

    FMCSA

    Contractor:

    FTA

    TPA:

    FRA

    Consortium:

    PHMSA

    Federal:

    USCG

    State:

    Other Federal:

    Other:

    Other State:

    Other:

    Other:

    Contact Information:For any questions or requests for guidance related to this audit protocol document, please contact:

    Stanley T. Kastanas, Director

    Office of Substance Abuse Policy,Investigations and Compliance

    Pipeline and Hazardous Materials Safety Administration (PHMSA)-Pipeline Safety (OPS)

    Washington, DC 20590

    Contact Number: 202-550-0629

    E-mail Address: [email protected]

    Auditor/Inspector Notes and Additional Information:

    Substance Abuse Program Protocols

    Table of ContentsAlcohol Misuse Prevention Program

    Protocol Area H. Alcohol Misuse Prevention Program, Plan and Policies

    Protocol Area I. Officials, Representatives, and Agents

    Protocol Area J. Required Alcohol Tests

    Protocol Area K. Alcohol Testing Devices

    Protocol Area L. Record Keeping and Reporting

    General

    Protocol Area M. Reporting of Drug and Alcohol Testing Results

    Protocol Area N. Public Interest Exclusions

    Alcohol Misuse Prevention Program

    Protocol Area H. Alcohol Misuse Prevention Program, Plan and Policies

    H.01Alcohol Misuse Prevention Program and Plan Scope

    H.02 Alcohol Misuse Prevention Policies

    Table of Contents

    H.01Alcohol Misuse Prevention Program and Plan Scope

    Verify that the Alcohol Misuse Plan meets the requirements of 199.202.

    H.01.a. Written Alcohol Misuse Plan

    H.01.a.Verify that the operator maintains and follows a written Alcohol Misuse Plan that conforms to Part 199 and Part 40 and that the plan contains methods and procedures for compliance with required testing, recordkeeping, reporting, education and training elements [199.202]:

    H.01.a. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    H.01.b.Covered Employees

    H.01.b.Verify that the Alcohol Misuse Prevention Program identifies the covered employees (as defined in 199.3) that are required to be tested for the presence of alcohol [199.1].

    H.01.b. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    H.01.c. Contractors Alcohol Testing Program

    H.01.c.If an employer utilizes applicable contractors or subcontractors who perform covered functions and conduct alcohol testing, education and training as part of the Alcohol Misuse Prevention Program [199.245], ], but separate from the employer, verify that there is a process in place and implemented to ensure compliance with Part 199 and Part 40.

    The contractor must allow access to property and records by the operator, the Administrator, any DOT agency with regulatory authority over the operator or covered employee, and, if the operator is subject to the jurisdiction of a state agency, a representative of the state agency for the purposes of monitoring the operator's compliance with the requirements of Part 199 and Part 40 [199.245(c)].

    H.01.c. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    H.01.d.DOT vs. Non-DOT Tests

    H.01.d.Verify that the Alcohol Misuse Prevention Program ensures that the DOT tests are completely separate from non-DOT tests in all respects [40.13].

    H.01.d. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    H.01.e. Employers Use of Third Party Providers in their Alcohol Misuse Prevention Program H.01.e.If an employer utilizes third party providers who perform covered functions and conduct alcohol testing, education, training and other appropriate services as part of the Alcohol Misuse Prevention Program, verify that there is a process in place and implemented to ensure compliance [40.341].

    H.01.e. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    H.02Alcohol Misuse Prevention Policies

    Verify that alcohol misuse prevention policies are established that meet the requirements of Part 40 and Part 199.

    H.02.a.Alcohol-Related Prohibited Conduct

    Verify that the Alcohol Misuse Plan ensures that a covered employee is not permitted to perform covered functions if the employee has engaged in conduct prohibited by 199.215 through 199.223 (as outlined below) or an alcohol misuse rule of another DOT agency [199.233].

    1. Having an alcohol concentration of 0.04 or greater [40.23(c), 40.285 and 199.215].

    2. Using alcohol while performing covered functions [199.217, On-duty use].

    3. Using alcohol within 4 hours prior to performing covered functions, or, if an employee is called to duty to respond to an emergency, within the time period after the employee has been notified to report for duty [199.219, Pre-duty use].

    4. A covered employee, who has actual knowledge of an accident in which his or her performance of covered functions has not been discounted by the operator as a contributing factor to the accident, is prohibited from using alcohol for 8 hours following the accident, unless he or she has been given a post-accident test under 199.225(a), or the operator has determined that the employee's performance could not have contributed to the accident [199.221, Use following an accident].

    5. Upon refusal of a covered employee to submit to a post-accident alcohol test required under 199.225(a), a reasonable suspicion alcohol test required under 199.225(b), or a follow-up alcohol test required under 199.225(d) [40.285 and 199.223, Refusal to submit to a required alcohol test].

    H.02.a. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    H.02.b.Available Resources for Employees

    H.02.b.Verify that the Alcohol Misuse Prevention Program assures that each covered employee who has engaged in conduct prohibited by 199.215 through 199.223 shall be advised of the resources available to the covered employee in evaluating and resolving problems associated with the misuse of alcohol. This includes the names, addresses, and telephone numbers of substance abuse professionals and counseling and treatment programs [40.285(b) and 199.243(a)].

    H.02.b. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    H.02.c. Alcohol Concentration of 0.02 or Greater

    H.02.c.Verify that the Alcohol Misuse Prevention Program assures that a covered employee is prohibited from performing or continuing to perform covered functions when found to have an alcohol concentration of 0.02 or greater but less than 0.04, until:

    1. The employee's alcohol concentration measures less than 0.02 in accordance with a test administered under 199.225(e); or

    2. The start of the employee's next regularly scheduled duty period, but not less than 8 hours following administration of the test [40.23(c) and 199.237(a)]

    H.02.c. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    H.02.d.Alcohol Misuse Program Educational Materials

    H.02.d.Verify that the Alcohol Misuse Prevention Program assures for providing educational materials that explain alcohol misuse requirements and the operators policies and procedures with respect to meeting those requirements [199.239(a)].

    The operator shall ensure that a copy of these materials is distributed to each covered employee prior to start of alcohol testing under this subpart, and to each person subsequently hired for or transferred to a covered position [199.239(a)(1)].

    Each operator shall provide written notice to representatives of employee organizations of the availability of this information [199.239(a)(2)].

    H.02.d. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    H.02.e.Educational Materials Content

    H.02.e.Verify that the educational materials made available to covered employees includes detailed discussion of at least the following [199.239(b)]:

    1. The identity of the person designated by the operator to answer covered employee questions about the materials.

    2. The categories of employees who are subject to the provisions of this subpart.

    3. Sufficient information about the covered functions performed by those employees to make clear what period of the work day the covered employee is required to be in compliance with this subpart.

    4. Specific information concerning covered employee conduct that is prohibited by this subpart.

    5. The circumstances under which a covered employee will be tested for alcohol under this subpart.

    6. The procedures that will be used to test for the presence of alcohol, protect the covered employee and the integrity of the breath testing process, safeguard the validity of the test results, and ensure that those results are attributed to the correct employee.

    7. The requirement that a covered employee submit to alcohol tests administered in accordance with this subpart.

    8. An explanation of what constitutes a refusal to submit to an alcohol test and the attendant consequences.

    9. The consequences for covered employees found to have violated the prohibitions under this subpart, including the requirement that the employee be removed immediately from covered functions, and the procedures under 199.243.

    10. The consequences for covered employees found to have an alcohol concentration of 0.02 or greater but less than 0.04.

    11. Information concerning the effects of alcohol misuse on an individual's health, work, and personal life; signs and symptoms of an alcohol problem (the employee's or a coworker's); and including intervening evaluating and resolving problems associated with the misuse of alcohol including intervening when an alcohol problem is suspected, confrontation, referral to any available EAP, and/or referral to management.

    H.02.e. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    Protocol Area H - Documents Reviewed

    Document Number

    Rev

    Date

    Document Title

    Protocol Area I. Officials, Representatives and Agents

    I.01Employer Responsibilities for Officials, Representatives, and Agents

    Table of Contents

    I.01Employer Responsibilities for Officials, Representatives, and Agents

    Verify that the Alcohol Misuse Prevention Program ensures that the employer remains responsible for all actions of their Officials, Representatives, and Agents (including service agents) as required by 40.11 and 199.245.

    I.01.a. Qualification Requirements

    I.01.a. Verify that Alcohol Misuse Prevention Program positions meet the applicable qualification requirements of Part 40 and Part 199 as follows:

    1. Screening Test Technician - 40.213

    2. Breath Alcohol Technician - 40.213

    3. Substance Abuse Professional (SAP) - 40.281

    I.01.a. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    I.01.b. Supervisor Training

    I.01.b. Verify that supervisors designated to determine whether reasonable suspicion exists to require a covered employee to undergo alcohol testing under 199.225(b) receive at least 60 minutes of training on the physical, behavioral, speech, and performance indicators of probable alcohol misuse. [199.241].

    I.01.b. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    Protocol Area I - Documents Reviewed

    Document Number

    Rev

    Date

    Document Title

    Protocol Area J. Required Alcohol Tests

    J.01Pre-employment Investigation and Alcohol Testing

    J.02 Post-Accident Alcohol Testing

    J.03 Reasonable Suspicion Alcohol Testing

    J.04 Return to Duty Alcohol Testing

    J.05 Follow-up Alcohol Testing

    Table of Contents

    J.01Pre-employment Investigation and Alcohol Testing

    Verify that the Alcohol Misuse Prevention Program ensures that pre-employment investigations for alcohol use are performed as required by 40.25 and that pre-employment alcohol tests are in compliance with 199.209(b).

    J.01.a. Verify that alcohol testing information [40.25(b)] is requested from previous DOT-regulated employers for any employee seeking to begin covered functions for the first time (i.e., a new hire or an employee transfers into a safety sensitive-position) [40.25(a)].

    In addition, verify that a covered employee must not perform their functions after 30 days from the date on which the employee first performed safety-sensitive functions, unless you have obtained or made and documented a good faith effort to obtain alcohol testing information from previous DOT-regulated employers.

    J.01.a. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    J.01.b.If the operator chooses to conduct pre-employment alcohol testing, verify that the operator:

    1. Conducts a pre-employment alcohol test before the first performance of covered functions by every covered employee (whether a new employee or someone who has transferred to a position involving the performance of covered functions) [199.209(b)(1)].

    2. Treats all covered employees the same for the purpose of pre-employment alcohol testing (i.e., you must not test some covered employees and not others) [199.209(b)(2)].

    3. Conducts the pre-employment tests after making a contingent offer of employment or transfer, subject to the employee passing the pre-employment alcohol test [199.209(b)(3)].

    J.01.b. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)

    Not Inspected

    J.02Post-Accident Alcohol Testing

    Verify that the Alcohol Misuse Prevention Program ensures that post-accident tests for the presence of alcohol are completed as required by 199.225(a).

    J.02.a.Verify that post-accident alcohol testing is performed:

    1. As soon as practicable following an accident (195.50) or incident (191.3) for each surviving covered employee if that employee's performance of a covered function either contributed to the accident or cannot be completely discounted as a contributing factor to the accident [199.225(a)(1)].

    2. Within two hours following the accident (195.50) or incident (191.3), otherwise, the operator shall prepare and maintain on file a record stating the reasons the test was not promptly administered. If a post-accident test is not administered within eight hours following the accident, the operator shall cease attempts to administer an alcohol test and shall state in the record the reasons for not administering the test [199.225(a)(2)].

    J.02.a. Inspection Results

    (type an X in exactly one cell below)

    Inspection Notes

    No Issue Identified

    Potential Issue Identified (explain)

    N/A (explain)