In This Issue

New York OQ Program Updates and Atmospheric Corrosion Monitoring Regulation

The New York State Department of Public Service has new regulations for its atmospheric corrosion control monitoring requirements. Operators are now required to conduct inspections of service lines for atmospheric corrosion every five years instead of every three years.

The Department also issued updated Operator Qualification (OQ) regulations. The OQ regulation changes include new definitions for Evaluator and Span of Control, and modified definitions for Covered Task and Qualified. The regulation for requesting Waivers to an OQ requirement has been deleted and replaced with a new regulation for Special Permits.

OQ program must reflect the operator’s actual operations (generic programs are not acceptable). The OQ program must document the training, the knowledge to be transferred and the skills to be demonstrated as part of the qualification process, in addition to the competencies of the evaluator. The training content must include Mutual Aid and the evaluation of risk for those engineering changes that increase risk. Operators must develop a Management of Change process to evaluate changes made in procedures, specifications, tools, materials of construction, and technology that would impact covered tasks.

New requirements for qualification include a secure testing environment, automatic no-pass criteria for incorrect responses to questions about Abnormal Operating Conditions, and a 48-hour waiting period between training and testing.  Written tests and performance observations are required. Records of the evaluation process must be collected and maintained for as long as the individual is responsible for the covered task role and then for five more years.

OQ programs must include OQ program performance effectiveness metrics and a review of those metrics at least once every two years. The regulation contains the minimum list of metrics, primarily documenting the causes of occurrences when a covered task performance is inadequate. The metrics cover categories ranging from inadequate training materials, delivery, and the qualification process, to not following procedure. The metrics also include an evaluation of whether the Span of Control was inadequate or not followed.

If you have questions or need assistance in your Operator Qualification Program, please contact Jessica Foley. The compliance date for the new OQ programs is April 1, 2023.