Operator Qualification

1
Operator Qualification

• ASME B31Q Standard Development Review

2
Disclaimer

• We are presenting this based on our personal
  understanding of the process and drafted
  document, and are not speaking on behalf of ASME.

3
Rule Dissatisfaction

• CONGRESS included language in H.R. 3609 Pipeline
  Safety Reauthorization Act of 2002
• NTSB labels Operator Qualification as
  unsatisfactory in 2002
• Office of Pipeline Safety issues 13 areas they
  consider as gaps in the rule and find rule
  violations
• 36 of audits have findings
• 12 of audits are given Notice of Probable
  Violations

4
Rule Dissatisfaction (contd)

• Operators find there to be inconsistent rule
  interpretations
• Contractors see no consistency in Operator
  programs and are required to qualify for the same
  task using different methods
• Individuals have been unable to link work
  experience, past training or certifications to
  qualifications

5
OPS 13 Perceived Gaps

• Scope of OQ inspections
• Lack of identified knowledge, skills and
  abilities
• Re-evaluation intervals
• Maintenance vs. new construction
• Treatment of Emergency Response
• Missing covered tasks (excavation)
• Extent of documentation

6
OPS 13 Perceived Gaps

• Generic vs. task specific Abnormal Operating
  Conditions
• Treatment of training
• Criteria for small operators
• Use of directing and observing
• Noteworthy practices
• Persons contributing to an accident

7
Rewind

• Five public meetings held in early 2003
• New supplementary rule making was developed and
  was issued in 2004
• Addresses training, requalification frequencies
  and requires changes to program to be submitted
  to OPS
• Industry and OPS agree to develop a new standard
  that will holistically address qualification of
  pipeline personnel

8
Proposal

• Office of Pipeline Safety agrees to participate
  with industry in developing an Operator
  Qualification standard that includes both
  prescriptive and performance aspects.
• If the standard is acceptable it will be
  incorporated into the regulation by reference in
  2005 or 2006.

9
Warning

• OPS has stated that if we are
  not successful in developing this
  standard they will rewrite the regulation for
  us.

10
ASME B31Q

• American Society of Mechanical Engineers (ASME)
  selected as entity to help develop and house
  standard
• ASME B31Q committee selected
• State and Federal Regulators
• Operators from all segments of the industry
• Contractor community
• Industry Associations
• Trade Associations
• Vendors

11
ASME B31Q (contd)

• Standard will have both prescriptive and
  performance based aspects
• Require processes and documentation
• Require knowledge and performance components
• Standard will include non-mandatory appendices
  which allows operator to make choices

12
ASME B31Q (contd)

• Standard Development
• Based on technical solutions
• Meets stakeholder needs (Regulators, Operators,
  Contractors and Vendors)
• Agreed upon by consensus
• Built on a framework that OPS can utilize when
  developing a future rule
• Utilizes the red faced test
• Do the right thing

13
ASME B31Q (contd)

• Will be built on Safety and Integrity NOT
  Operations and Maintenance
• Definitions and terminology will be standardized
• Program elements and process requirements will be
  standardized
• Portability will be recognized as a key measure
  of success

14
ASME B31Q Benefits

• Standardized task list
• Standardized requalification frequencies
• Identifies key qualification components
• Allows for portability
• Rationales are embedded in document
• Accepted by OPS
• Reduction in future changes to rule
• Meets many of the needs identified by the focus
  group working on certification of control center
  personnel

15
B31Q Standard Content

• Foreword
• Introduction
• Definitions
• References
• Qualification Program
• Determining Covered Tasks
• Abnormal Operating Conditions
• Training

• Evaluation
• Qualifications
• Portability
• Program Effectiveness
• Communicating the Qualification Program and
  Managing Changes
• Documentation Requirements
• Bibliography

16
Standard/Rule Comparison for 13 Issues

• Standard
• Safety Integrity
• 2-part Test
• Inclusion of construction and excavation
• Emergency Response addressed
• Training addressed
• Subsequent qualification intervals required with
  guidance on development and a requirement for
  monitoring

• Rule
• OM
• 4-part Test
• Exclusion of construction and other tasks
• Emergency Response not addressed
• Training not addressed
• Subsequent qualification intervals required for
  each task

17
Standard/Rule Comparison for 13 Issues (contd)

• Standard
• Program Review addressed
• Specific direction required for field supervision
  in the form of span of control for each covered
  task
• Analysis of appropriate evaluation method(s)
  required for each task
• Documentation requirements specified

• Rule
• Program Review not addressed
• General requirements for direction and
  observation of non-qualified individuals
• List of acceptable evaluation methods
• 4 specific documentation requirements

18
Example Prescriptive Alternatives

• Specific requirements of policies, procedures,
  processes, and responsibilities to document in
  the written program
• Acceptable methods to determine covered tasks
• AOCs that can be adopted
• Evaluation process requirements for each method
• Suspension and reinstatement, or revocation
  process or procedure required

19
Example Prescriptive Alternatives

• Span of control ratio maximum of 15
• Acceptable methods to determine subsequent
  qualification interval
• Subsequent qualification interval maximum of 5
  years
• Required tracking of 2 specific measures of
  program effectiveness
• Process required for rating the impact of a
  change to the program

20
ASME B31Q Timeline

• December 2005 ? completion of ASME consensus
  standard
• 2006 ? OPS review
• 2006 or 2007 ? Incorporate in CFR by reference
• 24 - 36 months after regulatory change ? Meet
  regulatory and standard requirements (time frame
  being discussed)

21
ASME B31Q To Date

• Informal public comment period provided in
  February 2005
• Public comments reviewed and discussed during
  Houston and Nashville meetings
• B31/B31Q Vote on standard May/June 2005
• Public comments November/December 2005
• Response to public comments, document revisions
  and final vote 1st quarter 2006
• Document approved for Technical Content
• Expected ASME publish date 3rd quarter 2006

22
ASME B31Q Unknowns

• Will standard be accepted by industry?
• Will OPS accept the program?
• Partially
• In total
• Or accept with changes
• When will the CFR be updated?
• What time frame will be given for program
  implementation?
• What will it cost to implement?

23
Questions