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March 12, 2025 at 10:00AM CST
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December 11, 2024
Could PSMS be Required by Law?
TOP 5 TAKEAWAYS:
1. Adopting PSMS is a good business endeavor for now, but another incident may prompt Congress to require PHMSA to enforce via rulemaking.
2. You don’t have to start PSMS from scratch, there are tools and assessment services available.
3. You need to find the right method to implement PSMS that fits your company.
4. Expect a second edition of API RP 1173 in 2025 that will have additional guidance for small operators.
5. PSMS training is required by API RP 1173.
May 15, 2024
What’s Next After GPAC’s Second Meeting on LDAR
TOP 5 TAKEAWAYS:
- Comments were closed for LDAR as of April 29th.
- If you are an operator, let your company leadership know there is impending regulation coming and it will affect your operations. You may want to provide the voting slides from GPAC so they are aware of the possible changes.
- Do not go out and buy new equipment until this regulation comes out; some of the rulemaking language may change.
- Prepare for change. This will affect operation and maintenance, training, and possibly OQ for most operators.
- When will this be final? The best estimate after this last GPAC looks like December of 2024. Two dates that must be accounted for: the publication date of the FR and the effective date of the rule that will be spelled out in the initial part of the FR. Will need to review to see if PHMSA followed GPAC recommendations on implement.
February 14, 2024
Unpack the GPAC Meeting on Leak Detection and Repair (LDAR Rule)
TOP 5 TAKEAWAYS:
- This is not yet a final rule. The GPAC committee votes on and recommends language, but PHMSA is the final authority.
- There’s still time to contact the involved associations before the next GPAC meeting, which begins on March 25th. Some topics you may want to comment on include: Gas gathering, Reporting, LNG and Hydrogen, Compliance deadlines, OQ, and Miscellaneous proposals.
- Do not go out and buy new equipment until this regulation comes out as a final rule. Some of the rulemaking language may be revised.
- Prepare for change. Whatever PHMSA decides, this will certainly affect operation and maintenance, training, and possibly OQ for most operators.
- The best estimate for the date of a final rule is June 1st or later.
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