Operator Qualification Program - Louisiana Department of Natural ...

ACKNOWLEDGEMENTS The Small System Operator Qualification Guide Material Project was part of
a national effort initiated by the United States Department of
Transportation, Research and Special Programs Administration, Office of
Pipeline Safety. In April of 2003, a team of individuals representing the liquid pipelines,
natural gas industry, and regulatory representatives from around the
country, were tasked with development of guidance for small system
operators of liquid and natural gas systems, to comply with the Operator
Qualification (OQ) Rule. The Small System Operator Task Force (SSOQ) in
this document has developed: o A list of definitions which may be helpful in understanding the OQ
Rule,
o Model Plan for compliance to OQ Rule,
o A "How to Guide" to comply with OQ,
o Guidance material which explains OQ audit protocols, which will be
used to review an operator's OQ program. The following SSOQ members are recognized as experts in their fields and
have given generously of their unique knowledge. They were directly
involved in the development of this guide material. Richard G. Marini - Co-Chair - New Hampshire - Regulatory
Michael Comstock - Co-Chair - City of Mesa, Arizona - Municipal
Bert Kalisch - American Public Gas Association
Daren Gilbert - California Regulatory
Dave Hraha - Iowa Municipal Organization
Don Stursma - Iowa Regulatory
Glen Tong - California Regulatory
Jim Hotinger - Virginia Regulatory
John Gawronski - OPS Consultant - Regulatory
Ken Taylor - White Mountain Oil Company - Liquid
Lane Miller - Transportation Safety Institute - Regulatory
Mike Bostic - Dennbury Company - Liquid
Massoud Tahamtani - Virginia Regulatory
Phil Bennett - American Gas Association
Rudy Parcel - Iowa Municipal Organization
Stanley Kastanas - OPS - Regulatory
John Erickson - American Public Gas Association This guidance material was implemented under the sponsorship of the U.S.
Department of Transportation. The material relies on sources representing
the best opinion on the subject at the time of publication. However, it
should not be assumed that all acceptable safety measures and procedures
are mentioned in this manual. The reader is referred to the Code of
Federal Regulations (49 CFR Parts 190-199, Part 40 and also NFPA 58 & 59)
for the complete pipeline safety requirements.
Characteristics of a Small System Operator All stakeholders in the pipeline industry fully support the operator
qualification (OQ) protocols developed by the U.S. Department of
Transportation's Office of Pipeline Safety (OPS) in response to the
Pipeline Safety Improvement Act of 2002. It is also recognized there is a
need for effective guidance for small system operators (i.e., those with
less complex gas distribution systems) about how to comply with the
protocols. In response to this need, federal and state pipeline safety
regulators as well as representatives of small systems committed to develop
that guidance and a set of criteria to assist operators who operate less
complex pipeline systems. The one constant and underlying goal of the group developing the
characteristics of a small system operator, and their protocols, was to
ensure that the level of safety provided by OPS' OQ process was maintained
and the effectiveness of the rule was not compromised. The fundamental rationale for having a different set of criteria for small
system operators is that many of these operators have a less complex system
and management structure. Therefore, such an operator does not need many
of the processes and formal management structure described in the current
OQ protocols. Both pipeline safety regulators and the regulated industry
need to share a common understanding of the "general characteristics" of a
small system operator to ensure appropriate protocols application during a
compliance audit. A number of system characteristics were discussed by the government-
industry team in determining-what is a "small system operator?" To provide
general guidance, two characteristics are discussed below. 1. Resources. Smaller systems have fewer resources available than larger
systems, however all operators must comply with the same pipeline
safety regulations. Smaller systems have:
(i) Less complex systems than larger operators;
(ii) Fewer individuals;
(iii) Less complex management structures;
(iv) Few layers of management, if any, between the OQ Plan
Administrator and its personnel performing covered tasks. 2. Number of employees performing covered tasks. While this is part of
Characteristic 1 above, the government-industry task force agreed that
a system with five or fewer individuals performing covered tasks is
likely to be a "small operator." The government-industry task force
also agreed that, depending on other relevant factors, a system with
more than 10 individuals performing covered tasks could be determined
to be a "small operator." These factors are not exclusive in determining a "small operator." It is
important to remember guidance material which applies to large operators
also applies to small operators. In providing this supplemental guidance
for small operators, the team recognized that the state program managers
have the authority and must also have the flexibility in making that final
determination in a fair consistent manner. Again, the elements of OQ compliance should be the same regardless of size;
none of OPS' criteria has been eliminated. The small system operator's
protocol elements have been structured to reflect that smaller operators
require less formal and less complex OQ compliance programs.
Table of Contents Page Chapter I - Guidelines for Developing an Operator Qualification Program Introduction I-1
Prepare a Written Operator Qualification Plan I-1
Identify Covered Tasks I-2
Evaluate Individuals Who Perform Covered Tasks I-3
Allow unqualified individuals to perform a covered task if directed
and observed by an individual who is qualified I-5
Post Accident/Incident Evaluation I-5
For Cause Evaluation I-6
Communication of Changes I-6
Establish re-evaluation intervals I-6
Training I-6
Record Keeping I-7
Record Retention I-7
Contractors I-7
Record Keeping for Contract Personnel I-8
Inspection Protocols I-8
Chapter II - Definitions II-1 Chapter III - Operator Qualification Protocols For Compliance Inspection
Process Statement on the Role of Protocols III-1
Element 1 III-2
Element 2 III-8
Element 3 III-12
Element 4 III-15
Element 5 III-19
Element 6 III-22
Element 7 III-23
Element 8 III-25
Element 9 III-27 Appendix A - Iowa Sample OQ Program A-1 Chapter I Guidelines for Developing an
Operator Qualification Program
Introduction These guidelines were prepared by a team of industry and government
pipeline safety and training experts to assist small operators and master
meter system operators to develop programs to ensure that individuals who
operate and maintain these systems are qualified for the work they perform.
Operators are required to prepare and follow an OQ program by federal
regulations at 49 CFR 192 Subpart N and 49 CFR 195 Subpart G, as well as
regulations adopted by some states. OQ programs must identify each individual, whether it be an employee of the
operator or an employee of a contractor hired by the operator, who performs
covered operations or maintenance activities on the piping system. The OQ
program must also identify the "covered tasks" that each individual
performs and ensure that each individual is tested to ensure they have the
necessary knowledge, skills and abilities to perform each task, as well as
to recognize and react to emergencies that may arise while performing these
tasks. The process the operator follows to accomplish these objectives must
be in writing. Records of the tests and other actions required in the plan
must be made available for inspection by state and federal pipeline safety
inspectors. The following steps should be considered when preparing an operator
qualification program. Prepare a Written Operator Qualification Plan The regulations require that you prepare and follow a written OQ plan that
at minimum includes the following eight provisions: 1. Identify covered tasks (operation and maintenance activities
affecting the integrity of the pipeline and required by the safety
code);
2. Evaluate individuals performing covered tasks to prove that they
are qualified;
3. Allow individuals who are not qualified to perform a covered task
if directed and observed by an individual who is qualified;
4. Evaluate an individual if there is reason to believe that the
individual's performance of a covered task contributed to an
incident;
5. Evaluate an individual if there is reason to believe that the
individual is no longer qualified to perform a covered task;
6. Communicate changes that affect covered tasks to individuals
performing those covered tasks;
7. Establish re-evaluation intervals; and
8. Describe how training will be used in the OQ program where
appropriate (new hires, refresher training fo