PHMSA Annual Meeting: Promoting Safety and Continuous Improvement in Hazardous Materials Transportation

1. Pipeline and Hazardous Materials Safety Administration (PHMSA)Independent Inspection Agency (IIA) Annual Meeting IIA Annual Meeting Washington D.C. November 14, 2017 Presented by : PHMSA Staff Pressure Vessels Division (PHH33) Pipeline and Hazardous Materials Safety Administration (PHMSA)

2. Independent Inspection Agency (IIA) Meeting Rachel A. Meidl, D.LP., CHMM Deputy Associate Administrator Office of Hazardous Materials Safety Pipeline and Hazardous Materials Safety Administration (PHMSA) November 14, 2017

3. U.S. Department of Transportation Secretary Elaine L. Chao Deputy Secretary Jeffrey A. Rosen

4. PHMSA Administrator Howard R. Elliott Deputy Administrator Drue Pearce

5. DOT Key Priorities • Safety • Infrastructure • Innovation • Accountability

6. Promoting SMS in Federal Gov’t PHMSA SMS Principles: • Management commitment to safety • Value, maintain, and operate risk management processes • Assess processes and procedures and validate systems • Measure and assess safety performance indicators and targets • Leverage emerging trends, metrics, investigations and inspections • Empower and invest in our people to advance our mission. • Internal and external collaboration and communication.

7. Voluntary Compliance System • Foster cooperation to proactively reduce regulatory oversight for companies investing 3rd party audits and ISO Standards for hazmat activities. • Compliment the current structure of the Systems Integrity Safety Program (SISP) • Reduced schedule for routine inspections • Focus inspection staff on higher risk companies • By 2019, Voluntary Compliance System criteria will be established, benefits outlined.

8. Quality Management and Continuous Improvement OHMS has implemented several process and performance improvement initiatives: • Data Operations Process and Procedures Review and Development (Pilot Program) • OHMS Process and Procedures Review and Development

9. Implementation of Data Operations Quality Management System (QMS) 1. Develop and Implement the QMS • Quality Manual • Performance Objectives • Standard Operating Procedures • Work Instructions and Forms 2. Evaluate Performance under the QMS • Develop performance metrics (existing, new) • Collect baseline and trend data on performance (monthly, quarterly) • Conduct audits and management reviews to identify areas for improvement 3. Adjust SOPs based on audit / management review findings

10. Quality Management and Continuous Improvement Data Operations Benefits Clarification of Data Operations responsibilities Lag reduction Increased accountability Contributors and dependencies outside of Data Operations identified Checks and balances built into process Documentation requirements identified throughout the process (e.g. work instructions and forms) Stakeholder Benefits Improves the quality of Incident Data Improves the timeliness of Incident Data Provides a better level of customer service for stakeholders Provides a platform for voicing opportunities for continuous improvement

11. OHMS Process and Improvement OHMS Benefits Established performance objectives Develop and documented guidance to hold staff accountable Well defined and standardized process documentation Improved direction and consistency of outputs Increased awareness of stakeholder requests Generated opportunities for continuous improvements • Operational efficiency • Established a foundation for measuring performance

12. PHMSA’s 3rd Party Agencies • Independent Inspection Agencies (IIA) • Designated Approval Agencies (DAA) • 3rd Party Packaging Labs • Fireworks Certification Agency (FCA)

13. Questions?

14. Our Mission015 IT Portfolio PHMSA's mission is to protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives.

15. Discussion PointsFY2015 IT Portfolio • IIA approval letter provisions • IIA White Paper effects on PHMSA and IIA’s • IIA Renewals Upcoming

16. Discussion Points (Cont.) • Application Technical Review Process • Regulatory Cooperation Council • Field Operations/Enforcement

17. Updated Approval Letter Provisions/Language Diane Jones, Pressure Vessels Branch (PHH33)

18. Updated Approval Letter Provisions/Language • IIA approval letter provisions • Expiration Dates/Renewals • Method of Manufacturing in application/cover letter

19. Approval Letter Language Changes/Additions • Modifying IIA Approval Letter • Revising current provisions in accordance with new 49 CFR Regulations • Adding new provisions to incorporated new policies • Eliminating outdated provisions for accuracy.

20. Approval Letter Language Changes/Additions (cont.) • New Provisions: • Design Change Provision • UN ISO Provision • Transport Canada Provision

21. Expiration Dates • Verify IIA Approval Letter Expiration • Submit Renewal Application at least 60 days in advance (49 CFR 107.705C) • Early Renewal is acceptable

22. RENEWALS • List all manufacturers you are representing as their IIA: • CA Approval Number • Facility Address and Point of Contact • List approved cylinders for each manufacture

23. Method of Manufacturing • Specify the process of manufacturing of cylinders for all applications for all applicants: • New • Renewal • Modification

24. Cover Letter • Submit a cover page with all applications: • New • Renewal • Modifying • Items on the Cover Page: • Manufacturer’s Name • CA Approval Number • Approved Cylinders • Method of Manufacturing

25. Cover Letter (cont.) • Modification of New Designs: • Identify the CA Approval Number and M# • Identify Method of Manufacturing • Specify the Cylinder Specification for new design • Include Manufacturer CA Approval Number

26. Questions? Any Additional Questions and/or Concerns? Diane Jones Transportation Specialist PHMSA Approvals and Permits Division PHH-30 Pressure Vessels Branch PHH33 East Building, E21-208 1200 New Jersey Ave., SE Washington, D.C. 20590-0001 diane.jones@dot.gov

27. IIA Responsibilities Neil Benninghoven, Pressure Vessels Branch (PHH33)

28. IIA Responsibilities • Upcoming Approval Renewals • White Paper Introduction • IIA Role in Approvals Process • Questions

29. Upcoming Approval Renewals • Domestic IIA Approval’s • PHMSA’s Plan • Application’s

30. Upcoming Approval Renewals (cont.) • Domestic Approvals Expire in 2018 • Ensure Application is received 60 days prior to expiration date as per 49 CFR 107.705 (c) • Expect Field Operations review of all renewal applications

31. Upcoming Approval Renewals (cont.) • Pressure Vessels branch will work with Field Operations staff to complete renewal process • PHMSA currently developing an action plan to ensure timely renewals of all IIA applications • Ensure application package is complete to avoid any delays in the process (IAW 49 CFR 107.705 & 107.803)

32. Upcoming Approval Renewals (cont.) • Renewal applications shall be submitted at least 60 days prior to the expiration date listed on the original approval to approvals@dot.gov. If a complete and conforming renewal application is received pursuant to 49 CFR, Parts 450-453 under the provisions of 49 CFR § 107.705 at least 60 days prior to the expiration date, the approval will remain valid and will not expire until final administrative action on the application for renewal has been taken by PHMSA.

33. Upcoming Approval Renewals (cont.) • What this means to you is, if you submit your application at least 60 days prior to the expiration date, your approval does not expire until PHMSA make a determination on your renewal application. If it takes a year to process the application, you are still able to perform your duties under the old approval letter IF your application is received prior to the 60 day mark.

34. IIA White Paper Introduction • Increased role in the approval of DOT specification cylinders design changes • Increased reporting requirements to report those “approved” designs now not covered under the approval letters.

35. IIA White Paper Introduction • New Manufacturing • The current process doesn’t allow the IIA to choose and send samples to the United States without a representative from PHMSA being present. Now the IIA’s will submit the samples with the initial application so all testing is complete prior to the arrival of the Field Operations staff for approval audit.

36. IIA White Paper Introduction • New Manufacturing (cont.) • If the samples sent pass testing and the designs and SOP’s are approved by our Engineering Division, both the IIA and the manufacturer will be granted a 2 year provisional approval to conduct business. During that 2 year period Field Ops will set up a time to conduct the Fitness Inspection. If the Company is found FIT, they at that time will receive the full 5 year approval.

37. IIA White Paper Introduction • New Manufacturing (cont.) • If the Field Ops staff finds the applicant UNFIT the approval letter will be terminated at that point and a recall initiated by both the IIA and manufacture will begin. The progress of the recall will be reported monthly to PHMSA until complete. The application process will then begin over for both applicants.

38. IIA White Paper Introduction (cont.) • Increased Field Operations oversight • Update Standard Operating Procedures (SOP) for Duties of the Inspector (needed for renewal)

39. Role in Approvals Process • Audits Reports will be taken heavily into account when granting provisional approvals to new manufacturers. • RIN audit reports for overseas applicants need to list any discrepancies noted during the inspection. • An IIA is NOT needed to add a Special Permit or UN ISO if the testing method is same as RIN holder is already approved for.

40. Role in Approvals Process (cont.) • Detailed SOP’s need to be included for each location (new or renewal applications) you are performing the duties of an IIA. • Review the manufacturers application prior to submittal to avoid any mistakes that can cause a delay in the approvals process. • Include a cover page with application to explain the purpose of application.

41. Role in Approvals Process (cont.) • Applications are not required by you when manufacturer is requesting an additional design approval under the current approval program. • Applications received from RIN holders after the 60 day mark do not get preferential treatment if you label the audit report “Recommended for expedited approval”

42. Questions

43. Application Technical Review Process Andrea Smith – Brian Moore, Engineering and Research Division (PHH22)

44. PHMSA PHH22’s Application Review (cont.)5 IT Portfolio • Technical Review Process Overview • DOT Cylinder Specification Requirements • Calculations • Design Qualification Testing • Batch Testing • Common Errors • Missing Information (e.g. test results, drawings, calculations) • Incomplete Drawings • Illegible Documents • Incorrect Calculations • Incorrect or missing pagination • Impact of Common Errors on Applicant • Delay in issuance of CAA

45. PHMSA PHH22’s Application Review\’s FY2015 IT Portfolio

46. PHMSA PHH22’s Application Review (cont.)5 IT Portfolio

47. PHMSA PHH22’s Application Review (cont.)5 IT Portfolio

48. PHMSA PHH22’s Application Review (cont.)5 IT Portfolio

49. PHMSA PHH22’s Application Review (cont.)5 IT Portfolio

50. PHMSA PHH22’s Application Review (cont.)5 IT Portfolio