OQ 2: The New Direction in Operator Qualification

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OQ 2 The New Direction inOperator Qualification
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The Reasons for OQ2

• Inadequacies Observed in Operator OQ Program
  Plans
• Need for Structure in Inspection Process

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The Reasons for OQ2

• National Transportation Safety Board Closure on
  OQ
• Potential Congressional Imposition of
  Certification Requirements

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OQ2 Reality

• OPS Is Not Staying
• Enforcement of the
• Operator Qualification Rule

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OQ2 The Problem

• We are Quickly Approaching October 28, and
  Operator Program Implementation Issues Exist

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OQ2 The Problem

• A Surge of Inspection and Enforcement Activity
  Based on Clarified Regulatory Expectations would
  not be Productive

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OQ2 Regulatory Goals

• Ensure That All Persons, Including Contractors,
  are Qualified to Perform Covered Tasks (Same as
  OQ1)

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OQ2 Regulatory Goals

• Support Early Post-Implementation Inspections

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OQ2 Regulatory Goals

• Promote Uniformity of Inspection and Enforcement
  Federal and State

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OQ2 Regulatory Goals

• Identify Noteworthy Practices and Promote their
  Broader Use

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OQ2 Operator Goals

• Ensure that all Persons, Including Contractors,
  are Qualified to Perform Covered Tasks (Same as
  OQ1)

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OQ2 Operator Goals

• Evaluate OQ Program Plans Relative to Clarified
  Regulatory Expectations

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OQ2 Operator Goals

• Identify Noteworthy Practices and Promote their
  Broader Use

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OQ2 The Approach

• Implement a Two-Stage Inspection Approach

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OQ2 The Approach

• Institute Web-Based Communications to Convey
  Expectations Gather Issues

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OQ2 The Approach

• Develop Structured Inspection Protocols and
  Supporting Inspector Guidance (Like that Being
  Used With the Integrity Management Rule)

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OQ2 The Approach

• Require Training of Inspectors in Use of the
  Protocols

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OQ2 Two Stages of Implementation

• Stage 1 Inspectors will Focus on High Risk
  Areas Reinforce Expectations
• Begin Inspections after October 28, 2002

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OQ2 Two Stages of Implementation

• Stage 2 Comprehensive OQ Inspections
• Fully Implemented by June, 2003

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What Are High Risk Areas?

• Significant Elements of the OQ Process
• Process to Address AOCs
• Process to Manage Contractor Qualification
• Basis for Reevaluation Intervals

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What Are High Risk Areas?

• Perceived High Risk Tasks
• Control Center Operation
• Application of Pipe Coating
• Monitor for Internal Corrosion

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Features of Web-Based Communications

• Flow Diagram of Steps in Rule Implementation
• Rule Provisions
• Preamble Insights
• FAQs (Frequently Asked Questions)
• Inspection Protocols

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Features of Web-Based Communications

• The Ability to Pose Rule-Related Questions
• Structured Process for Developing and Posting
  Response to Questions

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Operator Qualification Rule Process Flow
2. Identify Covered Tasks and Related
Evaluation Methods
1. Document Program Plan, Implementing Procedures
, and Qualification Criteria
3. Identify Persons Performing Covered Tasks
No Longer Qualified
4. Evaluate Qualify Persons Performing Covered
Tasks, Including Recognizing and Reacting to
Abnormal Operating Conditions
Yes
Should Person be Reevaluated? (Questionable Perfo
rmance, Reevaluation Due)
5. Continued/Periodic Evaluation of Persons
Performing Covered Tasks
No
6. Monitor Program Performance, Identify
Analyze Potential Improvements
8. Manage Change
7. Maintain Program Records
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Operator Qualification Rule Example of
Performance Protocol
Determination of Reevaluation Interval for
Coating Application

• Performance Monitoring (Examples)
• Post-Installation Quality Check,
• Requirement to Apply Coating at
• Least Monthly to Maintain
• Qualification
• Qualified Inspector Periodically
• Observes Application Practice, and/or
• Qualified Independent Verifier
• Periodically Observes Application
• Practice

Performance Actively Monitored After Qualification
?
Initial Qualification Evaluation by (a) Written
Examination, and (b) Observation During
Simulation of Task Performance
Yes
No
Assign Minimal Reevaluation Interval (e.g., 12
Months)
Assign Reevaluation Interval Longer Than
Minimal (e.g., 3 to 5 Years)
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Information on OQ2

• Http//primis.rspa.dot.gov
• Http//www.tsi.dot.gov
• Http//www.ops.dot.gov
• Http//www.rspa.dot.gov

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Questions?