QUALIFICATION VERIFICATION AT YOUR FINGERTIPS

Transcription

1 QUALIFICATION VERIFICATION AT YOUR FINGERTIPS Abstract From the inception of the Operator Qualification Final Rule, operators, contractors, and inspectors alike have struggled with effectively and efficiently communicating accurate qualifications in real-time. Angela Sellers, MS August 2015

2 Table of Contents Introduction... 2 Industry Verification Complications... 2 Industry Solution... 3 The EWN Solution... 4 Steps to view active qualifications Step One Scan the QR Code Step Two Select a Company Task List View Real-Time Qualification or Certification Records day Expiration Notification... 7 ecard Updates and Enhanced Features... 7 Conclusion... 8 Works Cited... 8

3 Introduction Per 49 CFR 192 or 195, The OQ rule requires, at a minimum, that the following records be retained: identification of qualified individual(s); identification of the covered tasks the individual is qualified to perform; date(s) of current qualifications; and qualification method(s). Records supporting an individual's current qualifications shall be maintained while the individual is performing the covered task. Each operator is required to assure itself that all individuals, including contractors, performing covered tasks on or after 10/28/02 are qualified to perform those tasks. Operators can choose from several methods of record retention, but must demonstrate that individuals performing covered tasks have been qualified. The operator may choose to maintain records; may rely on the records maintained by the contractor (in which case a prudent operator should perform periodic audits of such records, or provide by contract that such records must be turned over to the operator in the event that the contractor ceases doing business for any reason); or may rely on records maintained and administered by a third party. Although the Operator Qualification Final Rule provides many options and avenues for obtaining qualification records, it also creates an implied mandate to verify qualifications for every individual performing covered tasks on a pipeline or pipeline facility. Furthermore, operator qualification programs are subject to field verifications by various oversight and investigative agency inspectors. Therefore, since the beginning of the Operator Qualification Final Rule, operators, contractors, and inspectors have struggled with effectively and efficiently communicating accurate qualification records between interested parties in real-time. Industry Verification Complications PHMSA, Pipeline and Hazardous Materials Safety Administration, has provided some guidance and suggestions for operators and contractors to ensure a qualified workforce. However, only pipeline operators are subject to the requirements of the DOT Rules. Individuals performing covered tasks on an operator s pipeline facility, including its own employees, contractors, sub-contractors, original equipment manufacturer s (OEM) representatives, temporary help, etc., must be qualified or perform covered tasks under the direct supervision of a qualified individual. Operators may require contractors, which supply individuals to perform covered tasks to:

4 a. Have their own OQ Program and provide documentation that these individuals are currently qualified to perform the assigned covered tasks. b. Belong to a Consortium which provides the required qualification evaluations and documentation, or c. Qualify those individuals under the Operator s own OQ Program; or d. Have an independent third party evaluate their qualification and provide the required documentation. Regardless of which alternative is chosen, the contractor must be operating under an OQ Program that the operator has verified as being compatible with its own qualification procedures, including the recognition of and reaction to AOCs identified by the operator. With each of these suggestions, a paper-based or computer-reporting-based system is required to verify qualifications. Paper-based reports allow for verification of qualifications as current as the day and time of the printed report. Furthermore, this approach lacks the ability to confirm the identity of the individual performing the covered task and lacks the ability to reflect any change in qualifications since the report was printed, such as expiration or suspension of qualifications. Industry Solution In an effort to address verification of identity for individuals performing covered tasks, PHMSA released the following statements regarding issuing and carrying ID cards: Carrying ID cards to document covered tasks that a person is qualified to perform is permissible but not required. Some means is needed to allow a supervisor or foreman to determine the covered tasks for which persons under his/her supervision are qualified. The issuance and possession of ID cards is one means by which a supervisor or foreman can make this determination. Other means could include an electronic database accessible to the appropriate personnel that contains qualification records of all persons qualified to perform covered tasks for the operator. Paper ( hardcopy ) records may also be appropriate. Positive identification of the individual performing the covered task may also be required in cases where the individual and his or her qualifications are unknown to the job supervisor. The operator should require a government-issued identification in order to confirm that the correct individual has reported to the job site for the performance of the covered task. However, this solution still lacks the ability to reflect real-time changes with regards to an individual s qualifications. As technology has become increasingly predominate throughout society, the energy industry has incorporated technology into many facets of daily operations. By incorporating and linking current technologies, a more comprehensive solution would be an electronic qualification card linked to a records management system via a QR Code (Quick

5 Response Code) with a photo of the individual. Having the electronic qualification card linked to the records management system enables real-time updates to be reflected within seconds, rather than at the next updated printing and distribution of the report. Currently, many free QR Code reader software applications (apps) are available for mobile devices. For no charge, an inspector or operator can download a QR Code reader app on their tablet or smart phone. Then, within seconds, verify an individual s identity by matching them to the photo on the electronic qualification card and scan the QR Code to determine all current qualifications for that individual. The EWN Solution ENERGY worldnet, Inc. has developed an ecard to meet this industry need. The EWN ecard is linked to the EWN records management system and reflects all associated companies with assigned task lists for the individual named on the ecard. Once the QR Code has been scanned, the most current, active qualification records along with the associated expiration date will appear. By allowing instant access to multiple company and industry standard task lists, operators and agency inspectors can quickly verify current qualifications for operator employees, mutual aid assistance for partnering operators, and contractor employees. In 2014, PHMSA released an OQ Enforcement Guidance regarding the mandate for achieving and maintaining compliance for qualification records of all personnel, contractors, subcontractors, and mutual assistance personnel: Operators may employ many databases and tools to track and accumulate information pertinent to the individual qualifications, and these resources must be well-linked or integrated so that everyone has consistent information and access to the information that might need it, especially field offices. EWN shares qualification records with data management services at the operator, contractor, or municipality s request to further assist in the consistent sharing of real-time current qualification records.

6 Steps to view active qualifications 1. Step One Scan the QR Code 2. Step Two Select a Company Task List

7 3. View Real-Time Qualification or Certification Records Operator Qualification Records Certification Records

8 4. 30-day Expiration Notification For a demonstration, please scan the QR Code of the ecard shown on the title page of this white paper with any QR Code reader. ecard Updates and Enhanced Features Since the original release of the EWN ecard, ENERGY worldnet, Inc. has enhanced the functionality of features available when viewing current qualifications or certifications. When viewing the current qualifications for an individual, selecting the blue drop down arrow on the left-hand side of each qualification will display the tasks involved to obtain the qualification and the methods used to establish each qualification. When viewing the certification of an individual, documents can be uploaded and attached to the certification record for online viewing. If the individual reviewing the qualification has the appropriate permissions, the attached document can be accessed on the screen at the time of viewing the certification record. Additionally, if the qualification or certification will expire within the next 30 days, an orange, triangular warning icon will appear next to the task name and the specific evaluation method(s) indicating the approaching expiration.

9 Conclusion The merging of current technologies, QR Code readers on mobile devices linked to data management systems, will simplify inspectors and operators processes to ensure and verify an individual s qualifications in the field with real-time accuracy in a matter of seconds. Additionally, the ecard empowers individuals to be proactive in remaining qualified to perform their assigned covered tasks. EWN s comprehensive ecard technology will help inspectors and Operators meet the mandates outlined in 49 CFR 192 and 195 in the most effective and efficient manner. Works Cited "Operator Qualification: FAQs." Operator Qualification. PHMSA. Web. 4 May OQ Enforcement Guidance ( ). III. Staff Manuals and Instructions. PHMSA. Web. 28 May