In This Issue

OQ update

As mentioned in last month’s newsletter, Duke Energy and INGAA hosted an OQ update meeting on August 28. Some of the items that were discussed in that meeting include:

  • OQ audits are still mostly “process” oriented, and not “content” oriented.
  • OQ audits are not currently looking in-depth at control room operator qualification programs.
  • OPS intends to conduct OQ audits in conjunction with regular compliance audits in the future. There won’t be a lot of audits specifically for OQ.
  • Re-qualification intervals should be determined on a task-specific basis.
  • OPS expects to see some quantitative limitations for work performed by “unqualified” individuals under the supervision of a qualified employee, such as a numerical ratio (i.e. 3 unqualified per 1 qualified). This should also include limitations on which tasks can never be performed by an unqualified person (welding is an example).
  • OQ should be expanded to include pipeline integrity management tasks, when those rules apply to a pipeline operator.
  • Make sure your OQ program and your O&M; manual are consistent, and that they are the procedures that are actually used by the field.
  • The new mini-OQ rule may be delayed until the end of this year.
  • The ASME B 31-Q standards committee is actively working on a “technically based” qualification standard, which should have a working draft by mid-2004.

The following items fall under the category of “I heard it, but I hope it isn’t really true”:

  • OPS is expecting operators to evaluate and accept / reject individual task qualifications provided by third parties, such as NCCER and MEA. For example, an operator should do an evaluation to determine if MEA’s qualification process for task XX meets the operator’s OQ program requirements – and so forth for every individual task qualification from every third party whose program the operator intends to accept. It may not be sufficient to simply accept all MEA, NCCER, etc. task qualifications as being acceptable, without a detailed, individual analysis of each task.
  • OPS expects operators to treat all third parties conducting covered tasks for the operator as contractors. This would include other pipeline company employees, who are themselves already covered by their company’s OQ program. For example, if a Shell pipeline employee did a covered task for an ExxonMobil pipeline (say, as part of a jointly operated facility), that Shell employee would have to be qualified under the ExxonMobil OQ program. It may not be good enough for ExxonMobil to rely on the fact that Shell’s OQ program is independently audited and approved by the DOT.