Since operator qualification training modules for a covered task may be generic and not specific to the operator, regulators expect operators to ensure that contractors in addition to the generic OQ module training are familiar with the operator’s O&M procedure for that covered task. This can be done by a review of the O&M procedure during training or a tailgate meeting just before the task is to be performed. Documentation of this review is recommended to demonstrate compliance. Note that this issue, like some others in OQ, is documented in detail in the PHMSA enforcement guidance rather than the OQ code regulation itself. I have attached the PHMSA OQ Enforcement Guidance FYI.
§ 192.805 Qualification program.
Each operator shall have and follow a written qualification program. The program shall include provisions to:
(b) Ensure through evaluation that individuals performing covered tasks are qualified;
PHMSA OQ Enforcement Guidance (8-25-2016):
PHMSA Operator Qualification Enforcement Guidance (2016), Specifically Contractor Example #44 under 192.805(b):
“There is no documentation that provides the necessary assurance that the procedures on which a qualifying vendor’s evaluations are based are the same as or consistent with those used by operator employees and contractors in the field.”
If you have any pipeline safety consulting needs, please do not hesitate to contact us.