Navigating the Code: Operator Qualification...Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide) Navigating the Code: Operator Qualification Joey Bass

Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)

Navigating the Code:

Operator Qualification

Joey Bass

August 2019


Operator Qualification or OQ


No OQ could cause an AOC


Covered Task

1. Performed on a pipeline facility;

2. Operations or maintenance task

3. Performed as a requirement of this part

4. Affects the operation or integrity of the pipeline.


Qualified

(a) Performs an assigned covered tasks; and

(b) Recognize and react to Abnormal Operating Conditions “AOC’S”.


Evaluations methods

• Written or oral examination

• History review

• Performance - on the job training or simulations

• Other assessment.


On the Job Performance

• PHMSA has determined that there are no covered tasks to date where observation of on-the-job performance is an adequate, sole method for examining or testing qualification; and;

• Observation of on-the-job performance does not measure the individual’s ability to recognize and react to abnormal operation conditions (AOC’s).


Covered Task (1 of 2)


Covered Task (2 of 2)

• A qualified individual performing a covered task should possess:

– Knowledge

– Skill

– Ability


Knowledge

• Understanding gained through experience or study

• Operational knowledge

• Written instruction

• An organization that correlates to pipeline facilities (NACE)


Skill

• Is a demonstrable competency to perform a given task well, arising from talent, training or practice.

• Previous working experience

• Working under supervision of a qualified individual

• Simulated exercises


Ability

• Is the capacity to do or act, physically and/or mentally.

• Ability is understood to be broader than simply “physical capability” and includes such attributes as mechanical ability.


Common task vs. Position Task

• Common tasks:

– Tasks required for safe operations, such as leak investigation, valve operation, and pinch-offs.

• Position specific tasks:

– Tasks required for specific personnel such as corrosion evaluation, weld inspection, and coating application.


Covered Task Examples

• Locating existing facilities

• Hot tapping and stopping

• Regulator calibration or repair

• Valve operation and maintenance


Qualified (1 of 2)


Qualified (2 of 2)

• The operator is required to

− qualify the tasks using the company program and

− ensure that contracted parties are qualified.


Qualified Responsibilities

• Operators must determine re-evaluation intervals

• Some covered tasks are identified standards. (API,ASME,NACE,PPI,)

• Operators must notify OPS (or State agency) of significant modifications to their program.


Significant Changes Examples

• Includes but is not limited to:

• Increasing evaluation intervals.

• Increasing span of control ratios.

• Eliminating covered tasks.

• Mergers and/or acquisition changes.

• Evaluation method changes such as written vs. observation.

• Wholesale changes made to OQ plan


Training (1 of 2)


Training (2 of 2)

• Define skills and knowledge.• Initiate qualification assessments.• Present developed audit-able training

program(s).• Measure performance/effectiveness of

qualifications.• Retain detailed records of classroom, field, and

simulated assessments.• Perform refresher and an ongoing performance

training program(s).


Training Records

• OQ records are required for all individuals and contractors under the operator qualification program.


Guidance Interpretation & Advisories


Interpretation

Interpretation #PI-09-0003 192, 195 Date: 6-24-2009

• Non-Employees including emergency personnel must be qualified to perform covered tasks.

• Notification on Safe Excavation Practices and the use of Qualified Personnel to oversee all Excavations and Backfilling Operations.


Advisory

Advisory Bulletin ADB-09-03 192, 195 1-17-2006

• Defined “Significant” and Observation of on-the-job performance” additionally requires operators to notify PHMSA or state entity of significant changes to their OQ programs.


Inspections (1 of 2)

• Does the training program provide adequate documentation?

• Is the training program being reviewed?

• What is the change process and how is it being implemented?

• Off the self plans verses the operators program


Inspections (2 of 2)

• Is training sufficient and specific for the covered task and include AOC’s?

• Is there criteria defined and a process established for the re-evaluation or re-training of personnel?

• Does the operator have personal that does not meet expectations?


Questions

Documents

Navigating the Code: Operator Qualification...Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide) Navigating the Code: Operator Qualification Joey Bass