PHMSA 2005 OQ Update Presentation

7/31/2019 PHMSA 2005 OQ Update Presentation

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OQ Update ~ 2005

Operator Qualification Rules 49 CFR Part 192 (Subpart N) Part 195 (Subpart G)


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Why is OQ So Important ???

One Example ------


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You've carefully thought out all the

angles You've done it a thousand times

It comes naturally to you

You know what you're doing; its what

you've been trained to do your wholelife

Nothing could possibly go wrong , right ?


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Think Again !!!


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OQ-2 History OQ-2 Included:

Revisiting Original OQ ExpectationsPreparation of Inspection Protocols

Development of FAQs Communication through Web Site(http://primis.rspa.dot.gov/oq/index.htm )
http://primis.rspa.dot.gov/oq/index.htmhttp://primis.rspa.dot.gov/oq/index.htm


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OQ-2 History (Contd)

Congress Weighs In (PSIA-2002)

OQ Standards and Criteria Must be inPlace by 12/17/03

Regulators Must Complete Initial

Inspections of all Operators by 12/17/05Pilot Program for Certification of PipelineControllers Must be Completed by

12/17/05


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OQ-2 History (Contd) Mini Rule (PSIA-2002)

Operators must provide TRAINING , as appropriate , to provide individuals withnecessary knowledge and skills

Failure of OPS to act (issue regs.) does notexcuse operators from requirement to comply


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OQ-2 History (Contd) Mini Rule (PSIA-2002)

Reevaluation intervals are correctfor task

Significant modifications to theoperators OQ program must becommunicated to OPS


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January 2003 San AntonioFebruary 2003 HoustonMarch 2003 Phoenix

April 2003 Atlanta

Public Meetings Conducted

OQ-2 History (Contd)


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One Problem: Definition of Qualified

Qualified means that an individual hasbeen evaluated and can:(a) Perform assigned covered tasks ; and(b) Recognize and react to abnormal

operating conditions .


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One Problem: Definition of Qualified

Which Individuals are Covered?Who Evaluates and How?How are Covered Tasks Determined?

What are AOCs ?What does Recognize and React Mean?


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Persons Covered by OQ Rule

Individuals Who Perform Covered Tasks:

Operator Employees

Contractor Employees

Subcontractor Employees

Other Entities Performing CTs


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Other Entities Performing Covered Tasks


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Statement on the

Role of OQ Protocols

OQ Rule is Performance-based , WhichImplies a Need for:

Management Practices & Procedures

Measurement of Program EffectivenessProtocols Support Rule/PSIA


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Statement on the

Use of OQ ProtocolsThe Role of Protocols

Checklist to Support Inspectors & Provide Consistency in Evaluating OQPrograms

Structured into Protocol Questions, Which are Paired Directly withPrescriptive and Non-prescriptiveRequirements of the Rule


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OQ Rule ~ Prescriptive

Requirements

192.809 Operator Must Meet Specified Dates ---Written Program By Apr 27 01

Personnel Qualified By Oct 28 02

Cannot Use WPHR Alone After Oct 28 02


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Observations from Early

Inspections: Findings (1)

Programs Varied Considerably in Maturity

Significant Differences in Number of Covered Tasks (Use of Subtasks)

Significant Differences in Tasks Deemed tobe Covered (Definition Issue)


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Program Performance Measures areTypically Non-existent

Many Written Programs Tended to

Parrot Rule Requirements WithoutThinking Through Procedures toImplement Program


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Inspections: Findings (3)Operators Place SignificantResponsibilities on Front-line Supervisorsfor Success of OQ Program

Absence of Evaluation Criteria ,Qualification Documentation andProgram Development set up Supervisors for Failure


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Inspections: Findings (3)Operators Differed in Treatment of

Some Outstanding Issues:

O&M Activities vs. New Construction (A Definition Problem)

Excavation Over Loaded PipelinesInclusion of Emergency Response TasksIntegration of Training Documentationinto the OQ Program


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Inspections: Findings (4)Operators Differed in Treatment of

Some Outstanding Issues:

AOCs (Task-specific, Often Integratedinto Individual Tasks & Evaluations;Generic AOCs then Treated Separately or Not Addressed in Some Cases)

Virtually No Formalized and DocumentedMethodology to Identify New AOCs from

Near -miss


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Observations from EarlyInspections: Findings (5)

Operators Differed in Treatment of Some Outstanding Issues:

Specific Guidance on Span-of-Control(for Use of Non-qualified Individuals)

Identifying Persons Contributing toIncident/ Accident:

Immediate Contribution (Easier)

Delayed Contribution (Harder)


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Inspections: Findings (6)Most Operators Treated Some Outstanding Issues Similarly:

Justification for Reevaluation Intervals was Subjective (No Evidence Provided Tying

Quantitative Performance Measures to theEstablished Intervals)Tendency to (Try to) Place the Compliance

Burden on Contractors (by Contract)


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Discomforting use of WPHR (Work Performance History Review )

to Pre -qualify Individuals


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Observations from EarlyInspections: Findings (8)

Rigor of Contractor Qualification VariedConsiderably, Leading to Strong Concern

About Adequacy of Operators ContractorQualification Procedures

Many Operators did not ConsiderReplacement of Out -of- Service Pipelines as O&M (a Pipeline Facility Definition Problem)


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Rigor of Evaluator Credentialing (orSelection) has Varied Considerably

Insufficient Level of Detail inEvaluation Process


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Inspections: Findings (10)Management of Change---

Guidance is Needed on Defining:Significance of ChangeCorresponding Impact on Qualification

Required Action to Retain Qualification


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Inspections: Findings (11)Large Variations in Plans to Evaluate

Program Effectiveness, Ranging from:No Specific Plan to Review Program

Formally Review Program asNeeded and Assignment of Responsibility for Periodic Program

Review


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Likely Future Events

Issuance of Focused Supplementary Rule(Advisory Bulletin published 11/26/04)

Documentation of Role of TrainingSupport for Reevaluation IntervalReporting of Significant Changes

Publication of B31.QB31.Q Standard


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Whos Developing the

B31.Q Standard?

Stakeholders under ASME Industry: Oil, Gas, Liquids, Offshore,Transmission and LDCs

VendorsContractorsRegulators (State and Federal)


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Scope of B31.Q Standard

This standard specifies the requirements for the qualification of individuals performing safety or integrity related tasks for the operation and maintenance of gas and hazardous liquid pipelines that are subject to

ASME B31.4 & B31.8. The standard establishes the processes to determine which tasks require

qualified individuals and the processes that may be utilized to obtain qualification. The standard also includes processes for training,requalification, documentation, quality control and requirements for management of change.


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Whats the status of thestandard?

B31.Q Committee meet

Draft on Web by February 2005 for PublicComment

Ball in OPS Court (OPS can ibr B31.Q in itsEntirety, Specific Sections, Sections with Changesor Additions, or do Nothing at all

If OPS I - 2006 to Take Effect andUntil 2008 to Comply


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Expected Benefits of B31.Q

Future Rule Changes Should be

MinimizedIMP Requirements are Embedded

Portability is Possible OutcomeWill Better Meet Stakeholders

Expectations (NTSB, Congress)


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Moving Forward with OQ


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Inspection Deadline

All Operators are to beInspected by

December 17, 2005, as Required by PSIA 2002


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Inspection Format

Use of 16 Protocol Questions,

Including Process, Procedure,and Records (Elements 1-8) Field Verification:

Review of Task Performance,Procedures, and Knowledge of

AOCs (Element 9)


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1

2

3

4


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Enforcement of theOQ Rule

Significant Efforts Underway toEnsure Consistency of Inspections

Enforcement of Rule may Vary Among Federal and State Authorities


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Enforcement of theOQ Rule

OPS will Utilize all Available Enforcement Tools to Address Inadequate Plans, Records,and Compliance with the Rule, Including:

(NOA) Notice of Amendment

(NOPV) Notice of Probable Violation (PCO) Proposed Compliance Order (PCP) Proposed Civil Penalty


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Distribution of Issued Enforcement Actions by EnforcementType

41%

21%

15%

15%

5% 3%

Notice of Amendment

Notice of Probable Violation

Proposed Civil Penalty

Compliance Order

Warning Letter

Letter of Concern

62% of OQviolations areNOPVs and

NOAs


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Staying Current

http://primis.rspa.dot.gov/oq/index.htm

http://www.tsi.dot.gov/divisions/pipeline/

pipeline.htm
http://primis.rspa.dot.gov/oq/index.htmhttp://www.tsi.dot.gov/divisions/pipeline/%0Bpipeline.htmhttp://www.tsi.dot.gov/divisions/pipeline/%0Bpipeline.htmhttp://www.tsi.dot.gov/divisions/pipeline/%0Bpipeline.htmhttp://www.tsi.dot.gov/divisions/pipeline/%0Bpipeline.htmhttp://www.tsi.dot.gov/divisions/pipeline/%0Bpipeline.htmhttp://primis.rspa.dot.gov/oq/index.htm


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Other Sources for Information

Thirteen OQThirteen OQImplementation IssuesImplementation Issues

May 6, 2003May 6, 2003


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Top OQ Issues To Date

Office of Pipeline Safety


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Summary Statistics by Protocol

Office of Pipeline Safety


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Word Documents: OQ Lessons Learned_021804.doc Enforcement Guidelines with Coments.doc OQ Audit Issues 8-13-01.doc OQ History.doc

(For Copies of PowerPoint Presentations and/or MSWord Documents, Contact: [email protected] )
mailto:[email protected]:[email protected]


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Questions ?