Transcript Operator Qualification (OQ)

Operator Qualification
(OQ)
Presentation to STEPS Network
Corpus Christi, TX
July 21, 2004
Background
• Pipeline Safety Act of 1992
• Accountable Pipeline and Partnership Act of 1996
• Operator Qualification Rule – August 27, 1999
– DOT Research and Special Programs Administration (RSPA)
• 49 CFR 192 Subpart G
• 49 CFR 195 Subpart N
• Pipeline Safety Act of 2002
• Pipeline Integrity Rule
• OPS Enforcement Protocols
Purpose of the OQ Rule
The purpose of the rule is to reduce
accidents related to human error by
ensuring that individuals who perform
covered tasks are qualified to perform
those tasks.
Definitions
Covered Task -- The rule describes a Four-Part
Test that each Operator must use to determine
whether an activity constitutes a “covered task”.
A covered task (is):
1.
2.
3.
4.
Performed on a pipeline facility; and
An operations or maintenance task; and
Required by 49 CFR 192 or 195; and
Affects the operation or integrity of the pipeline.
Definitions
Qualified – An individual must be able to:
– Perform the task; and
– Recognize and react to abnormal operating
conditions (AOC).
Definitions
Abnormal Operating Condition (AOC) – A
condition identified by the Operator that may
indicate a malfunction of a component or
deviation from normal operations that may:
1.Indicate a condition exceeding design limits; or
2.Result in a hazard(s) to persons, property, or
the environment.
Requirements
The rule requires Operators of pipelines
to develop a qualification program to
evaluate individuals for their ability to
perform covered tasks, and to recognize
and react to abnormal operating
conditions (AOC) that may occur while
performing covered tasks.
Requirements
August 27, 1999
–OQ Rule Published
October 26, 1999
–OQ Rule became effective
April 27, 2001
–Operators must have a written qualification
program in place
October 28, 2002
–Individuals performing covered tasks must be
qualified
Requirements
• Operator must develop a written OQ program
– Identify covered tasks
– Ensure that individuals performing covered tasks are
qualified (through evaluation)
– Allow non-qualified individuals to perform covered tasks
under the direction/observation of a qualified individual
– Evaluate any individual whose performance of a covered
task contributed to an incident or if there is reason to believe
he/she is no longer qualified
– Communicate changes that affect covered tasks to
individuals performing those tasks
– Identify re-evaluation intervals
• Maintain records
Requirements
Anyone performing a covered task must
be qualified, unless directed and
observed by a qualified person:
– Operator’s own employees
– Contractors
– Sub-contractors
– Other entities
Requirements
• Each Operator must maintain qualification
records which must include:
– Identification of qualified individual(s)
– Identification of covered tasks the individual is qualified to
perform
– Date(s) of current qualification
– Qualification method
• Records must be maintained while the
individual is performing the covered task and
retained for 5 years thereafter.
Requirements
• The rule allows for several methods of evaluation
–
–
–
–
Written examination
Oral examination
Work performance history review
Observation during:
• Performance on the job
• On-The-Job-Training
• Simulation
– Other forms of assessment
• After October 28, 2002, Work Performance History
Review may not be used as the sole evaluation
method
Challenges
Inconsistency
– Inconsistency in Operator programs, requirements and
inconsistency in regulatory expectations
Portability
– Contractors face the problem of qualifying their employees multiple
times because of different Operator requirements.
Change
– Changing requirements for Operators and contractors since
10/28/02.
OQ Rule
Protocols
Mini Rule
B31Q
B31Q
• Sponsored by ASME
• Originated from 13 unresolved issues during
development of OPS enforcement protocols.
• Industry group to develop a consensus standard that
Operators may use to manage their OQ Programs.
– Regulators
– Operators
– Contractors
– Organized Labor
– Vendors
• Scheduled to be finalized in late 2004.
• If OPS accepts the B31Q standard, it is intended that
the all or part of the standard will be incorporated by
reference into a revised OQ rule.
Enforcement Experience
• Regulated by DOT/OPS (interstate) and state
agencies (intrastate)
• Inspections driven by OQ protocols
• DOT goal to have all interstate Operators
inspected by end of 2004.
• Areas of regulatory focus:
–
–
–
–
–
Definition of construction vs. O&M
Use of Work Performance History Review
Adequacy of documentation
Operator specificity
Role of Operator field personnel in implementation
1776 Woodstead Court, Suite 200
The Woodlands, TX 77380
Telephone: 281-363-4001
Toll-Free: 800-426-1604
Fax:
281-363-2993
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Email: [email protected]