As mentioned in last month’s newsletter (March 2005 DOT Pipeline Compliance News), OPS issued a Final Rule that outlines certain requirements for personnel training, notice of program changes, government review and verification of programs, and use of on-the-job performance as a qualification method. This Direct Final Rule goes into effect July 1, 2005, if OPS does not receive any adverse comment or notice of intent to file an adverse comment by May 2, 2005.
On the first day of the OQSG User’s Group Meeting in Houston, a representative from the OPS was asked about this final rule and how the OPS plans to interpret and enforce. Several attendees were surprised to hear that the OPS currently interprets the new language to require operators to evaluate BOTH knowledge AND skills of operators performing covered tasks. This includes documentation of written or oral knowledge assessments AS WELL AS documentation of skills assessments of operators performing covered tasks. This interpretation provoked a lively discussion among the operators and contractors in attendance and was apparently reaffirmed with other OPS officials the following day.
The OPS also communicated that updated Operator Qualification Inspection Protocols will be made available to the public in the next few weeks. These protocols should provide additional guidance on how the OPS plans to enforce the revised OQ requirements. RCP will include the updated inspection protocols in the newsletter following their publish date.