Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Navigating the Code:
Operator Qualification
Joey Bass
August 2019
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Operator Qualification or OQ
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
No OQ could cause an AOC
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Qualified
(a) Performs an assigned covered tasks; and
(b) Recognize and react to Abnormal Operating Conditions “AOC’S”.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Evaluations methods
• Written or oral examination
• History review
• Performance - on the job training or simulations
• Other assessment.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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).
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Covered Task (1 of 2)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Covered Task (2 of 2)
• A qualified individual performing a covered task should possess:
– Knowledge
– Skill
– Ability
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Knowledge
• Understanding gained through experience or study
• Operational knowledge
• Written instruction
• An organization that correlates to pipeline facilities (NACE)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Covered Task Examples
• Locating existing facilities
• Hot tapping and stopping
• Regulator calibration or repair
• Valve operation and maintenance
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Qualified (1 of 2)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Qualified (2 of 2)
• The operator is required to
− qualify the tasks using the company program and
− ensure that contracted parties are qualified.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Training (1 of 2)
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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).
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Training Records
• OQ records are required for all individuals and contractors under the operator qualification program.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Guidance Interpretation & Advisories
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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?
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Questions