OQ NPRM: Effects on the Industry & What You Need to Know. Tom Meek, Compliance Director

Transcription

1 OQ NPRM: Effects on the Industry & What You Need to Know Tom Meek, Compliance Director

2 Session Overview 1. OQ 101 o A quick level set of OQ and how we got to where we are today 2. OQ NPRM Status o The latest information from PHMSA 3. Key Areas of the NRPM o What companies can do to prepare with key areas for consideration 4. Technology o Discuss how technology can help companies and what to look for 5. Integrity Management Advisory Bulletin ADB (April 10, 2017) o Training and Qualification for Integrity Management Program 2017 Veriforce, LLC. All rights reserved. 2

3 OQ 101 o PHMSA final rule effective date Oct o The OQ Rule remains in place o PHMSA NPRM July 2012 o Comment Period Closed o Utilities 5, Pipeline 9, Others 25 (Comments received) o Jan 26, OQ NPRM issues put on hold 2017 Veriforce, LLC. All rights reserved. 3

4 The OQ Final Rule without OQ What happened? o There was an election o There was an administration change o There was precedence in the delay Veriforce, LLC. All rights reserved. 4

5 OQ NPRM Update Overview Key proposed changes and additions o Expanded definition of covered task o o o New Construction Emergency Response Integrity Management o Focus on training as part of qualification o Apply Management of Change to OQ o Emphasis on program effectiveness review o Document, document, document 2017 Veriforce, LLC. All rights reserved. 5

6 Specifics Changes that will have greatest impact Scope Program Effectiveness Management of Change Training Evaluator Requirements Recordkeeping 2017 Veriforce, LLC. All rights reserved. 6

7 Scope Qualified individual has been evaluated and can: 1. Perform assigned covered tasks 2. Recognize and react to abnormal operating conditions 3. Demonstrate technical knowledge required to perform the covered task 4. Demonstrate the technical skills required to perform the covered task 5. Meet the physical abilities required to perform the specific covered task (e.g., color vision or hearing) 2017 Veriforce, LLC. All rights reserved. 7

8 Span of Control (SOC) A SOC ratio of 1:3 would mean that one qualified employee could direct and observe up to three unqualified employees. Q NQ NQ NQ 2017 Veriforce, LLC. All rights reserved. 8

9 Training Requirements Training for individuals performing covered tasks is required as part of qualification program o Knowledge, skills, and abilities (KSAs) to perform covered task in manner that ensures pipeline safety and integrity o Supplemental training on changes to procedures and specifications for covered task o Ability to recognize and react to generic and task specific AOCs 2017 Veriforce, LLC. All rights reserved. 9

10 Program Effectiveness Requirements Develop and implement a process to measure OQ program effectiveness o Effective = minimize human error due to lack of KSAs o Conducted once a year o Written process to evaluate and amend based on findings o Must include minimum measures defined by PHMSA to determine effectiveness o Number of occurrences o Qualified and non-qualified individuals involved in incident 2017 Veriforce, LLC. All rights reserved. 10

11 Evaluator Requirements oestablish criteria and training necessary to be an evaluator of individuals performing covered tasks omeasure and track evaluators performance 2017 Veriforce, LLC. All rights reserved. 11

12 Management of Change Requirements Establish and maintain a Management of Change (MOC) program ocommunicate and document changes that affect a covered task to anyone performing that task and supervisor Field employees Contractors Supervisors 2017 Veriforce, LLC. All rights reserved. 12

13 Recordkeeping Requirements Maintain Individual Qualification records ocovered tasks qualified oqualification methods and dates oaoc evaluation oevaluator name, date otraining required Retain these records for appropriate period 2017 Veriforce, LLC. All rights reserved. 13

14 Recordkeeping Requirements Maintain Program records oprogram effectiveness reviews oprogram changes olist of AOCs oprogram MOC notifications ocovered task list ofor each covered task: SOC ratios, reevaluation intervals, and evaluation methods oevaluator criteria and training Retain program records for appropriate period 2017 Veriforce, LLC. All rights reserved. 14

15 Expanded Scope orecognize new covered tasks oidentify, train, and qualify individuals performing those tasks oinclude additional items in evaluations, e.g., mental and physical ability oreview covered task difficulty, complexity and importance to determine SOC limitations o Consider operational conditions 2017 Veriforce, LLC. All rights reserved. 15

16 How Technology Can Help ocentral qualification tracking and reporting oevaluator training and performance ocovered task CBT and training management opolicy and procedure management omanagement of change communications ocentral capture/report on program effectiveness measures orecordkeeping 2017 Veriforce, LLC. All rights reserved. 16

17 Questions?

18 Tom Meek veriforce.com