Operator Qualification: Protocols
The following protocols have been written to assist federal and state pipeline inspectors who are evaluating operator's OQ programs. The protocols are not intended as enforcement instruments or to provide inspectors with additional enforcement authority, but rather are intended to provide inspectors with a template that they can use in the course of their inspections to ensure that operators comply with all elements of the OQ rule. The objective of the protocols is to ensure that the prescriptive requirements of the rule have been followed by operators. This objective will be accomplished by rigorously inspecting each operator's records to ensure that all persons performing covered tasks on pipeline facilities are properly qualified and that sufficient documentation is maintained for these individuals. Proper recordkeeping is a key component of the OQ rule. It is therefore important that inspectors be able to verify that records are maintained for all individuals performing covered tasks.
The OQ inspection form is organized around nine elements, including one for field verification. Each element has one or more associated protocol. Each protocol consists of 3 aspects: (1) a protocol number accompanied by the protocol subject or topic; (2) a protocol question(s) (sometimes followed by 'Verify' statements); and (3) guidance topics. The protocol topics have been structured into 'Protocol Question(s)' to guide inspectors through the OQ inspection process. Each protocol question is followed by 'Guidance Topics.' The guidance topics list characteristics that the regulator would typically expect to find in an effective OQ Program, and that are consistent with the intent of the regulatory language that accompanies each protocol. Some, all, or none of these characteristics may be appropriate depending on factors unique to each operator's OQ Program and pipeline assets. Operators should be prepared to demonstrate that their programs address each of these characteristics or to describe how their program will be effective in their absence.
Many of the protocol questions are followed by 'Verify' statements. These statements have been included because they can be directly traced to specific rule language. Therefore, compliance with each 'verify' statement should be confirmed. Many 'verify' statements (and protocol questions) are followed by a parenthetical statement that indicates that the statement or question is either 'enforceable' or 'non-enforceable'. If the 'verify' statement or protocol question is listed as non-enforceable, the statement or question is not enforceable under the rule, but is nonetheless an important consideration for the operator. Finally, should the inspection process reveal violations of prescriptive requirements of the rule, regulators will take appropriate enforcement actions. Should deficiencies be identified in how operators address program characteristics, inspectors will seek evidence of violations related to these deficiencies.
Significant inquiries seeking further information related to program characteristics will be communicated to the operator as an integral part of the inspection process.
1.01 Application and Customization of 'Off-the-Shelf Programs'
Does the operatorís plan identify covered tasks and does it specify task-specific reevaluation intervals for individuals performing covered tasks? [Enforceable]
1.02 Contractor Qualification
1.03 Management of Other Entities Performing Covered Tasks
1.04 Training Requirements (Initial Qualification, Remedial if Initial Failure, and Reevaluation)
1.05 Written Qualification Program
2.01 Development of Covered Task List
How did the operator develop its covered task list?
2.02 Evaluation Method(s) (Demonstration of Knowledge, Skill and Ability) and Relationship to Covered Tasks
2.03 Planning for Mergers and Acquisitions (Due Diligence re: Acquiring Qualified Individuals)
3.01 Development and Documentation of Areas of Qualification for Individuals Performing Covered Tasks
Does the operatorís program document the evaluation and qualifications of individuals performing covered tasks, and can the qualification of individuals performing covered tasks be verified at the job site?
3.02 Covered Task Performed by Non-Qualified Individual
4.01 Role of and Approach to 'Work Performance History Review'
Does the operator use work performance history review as the sole method of qualification for individuals performing covered tasks prior to October 26, 1999, and does the operatorís program specify that work performance history review will not be used as the sole method of evaluation for qualification after October 28, 2002?
4.02 Evaluation of Individualís Capability to Recognize and React to AOCs
5.01 Personnel Performance Monitoring
Does the operatorís program include provisions to evaluate an individual if the operator has reason to believe the individual is no longer qualified to perform a covered task based on:
- Covered task performance by an individual contributed to an incident or accident.
- Other factors affecting the performance of covered tasks.
5.02 Reevaluation Interval and Methodology for Determining the Interval
6.01 Program Performance and Improvement
Does the operator have provisions to evaluate performance of its OQ program and implement improvements to enhance the effectiveness of its program? [Non-Enforceable]
7.01 Qualification 'Trail' (i.e.,covered task; individual performing; evaluation method(s); continuing performance evaluation; reevaluation interval; reevaluation records)
Does the operator maintain records in accordance with the requirements of 49 CFR 192, subpart N, and 49 CFR 195, subpart G, for all individuals performing covered tasks, including contractor individuals?
8.01 Management of Changes (to Procedures, Tools, Standards, etc.)
Does the operatorís OQ program identify how changes to procedures, tools standards and other elements used by individuals in performing covered tasks are communicated to the individuals, including contractor individuals, and how these changes are implemented in the evaluation method(s)?
8.02 Notification of Significant Program Changes
9.01 Are field/job supervisors aware of their responsibilities as defined under the operator's OQ program?
9.02 Are the observed covered task(s) performed in accordance with appropriate operator-approved procedures, and are the procedures present at the job site?
9.03 Are the individuals performing the observed covered task(s) adhering to the operator-approved procedures as written?
9.04 Are the proper tools, techniques and processes detailed in the operator-approved procedures employed in the performance of the observed covered task(s)?
9.05 Are the qualifications of all individuals involved in performing the covered task(s) verified at the job site? Is this verification process performed as detailed in the operator's OQ program plan? Is this verification process applied to employees and contractors alike?
9.06 Are the qualified individuals performing the observed covered task(s) knowledgeable of how to recognize the applicable AOCs and what their expected reaction to the AOCs should be?
9.07 Are individuals not qualified to perform a covered task performing a covered task? If so, are the non-qualified individuals being directly observed by a qualified individual in accordance with the requirements of the regulation?
9.08 How are field/job supervisors informed of changes that affect the performance of covered tasks under their responsibility?
9.09 In cases where the field office is part of a subsidiary or separate district, is implementation of OQ program requirements consistent with other districts and the overall organization's OQ program?
9.10 How is performance of the covered task(s) reviewed/inspected in the field by internal auditors or third party inspectors?
9.11 What problems have been experienced in the field in implementing the operator's OQ program? If problems have been experienced, how have they been communicated back to the individual responsible for the OQ program?
9.12 How are Control Center operations coordinated with remote operations that are conducted with other operations personnel? Are these 'other operations personnel' qualified to perform the covered tasks being performed?