2.11 If an individual seeking qualification to perform a covered task fails the evaluation process, how many times can he/she be reevaluated?
Determining the number of times an individual can be reevaluated is up to the operator. An operator must not permit a candidate who fails the reevaluation process to perform the covered task until that person has passed the evaluation or is directly observed by a person who is qualified to perform the covered task. The Operator’s OQ Program should describe, in sufficient detail to avoid ambiguity or misinterpretation, how it will address failure to pass the evaluation process. If appropriate, remedial training and subsequent reevaluations can be offered. If reevaluation is offered, the operator should require the individual to go through a “cooling off” period following a failure to pass, in order to ensure that the individual is not relying entirely on short-term memory to pass the reevaluation process. Additionally, the operator should specify the number of failures that are acceptable before discontinuing evaluation efforts.
2.12 What is a reasonable time between failure to pass an evaluation and reevaluation?
The time between failure and re-evaluation may be affected by several considerations. The most important of these is ensuring that the reason for failure is recognized and addressed prior to reevaluation. If fundamental knowledge, skill or ability gaps are disclosed by the failure, additional training should be provided prior to reevaluation. The operator’s written program should describe how the operator identifies and corrects the cause(s) of failure before reevaluation.
2.13 Should operators implement measures to ensure that the procedures on which qualification is based are consistent with the actual practices implemented in the field?
A major purpose of the operator qualification rule is to eliminate job performance errors that might affect the integrity of pipeline systems. Such errors can be inadvertent (e.g., forgetting a step in implementation of a procedure) or systemic (e.g., practices that are inconsistent with written procedures, such as purposely ignoring SCADA system alarms because they are known to be inaccurate). Elimination of systemic errors is as important as eliminating inadvertent ones. Therefore, operators should incorporate into their qualification program provisions for ensuring that practices in the field are the same as those documented in the operator’s O&M Plan, which provide the basis on which persons are qualified. Such provisions might include field audits of on-the-job performance by separate audit units within the company.
2.14 What credentials must a person have to be an evaluator?
Operators may, but are not required to, establish criteria that an individual must meet to be an evaluator. Evaluators should, however, possess the required knowledge to ascertain an individual's ability to perform covered tasks and to substantiate an individual's ability to recognize and react appropriately to abnormal operating conditions that might occur while performing these activities. The evaluation process should be objective and consistent. To ensure this, evaluators should be knowledgeable about the subject tasks in order to conduct effective evaluations.
2.15 Must records be maintained documenting evaluator credentials?
The generation and retention of records to substantiate an evaluator's knowledge is a good practice. It demonstrates to regulators a good faith effort to comply with the spirit of the OQ rule. The generation and maintenance of records to substantiate an evaluator's knowledge is ultimately, however, at the operator's discretion.
2.16 Will the use of third party evaluation become a mandatory method of evaluation?
The OQ rule does not currently require the use of third party evaluators, nor is such a requirement anticipated.
Development and Documentation of Areas of Qualification for Individuals Performing Covered Tasks
3.1 Will qualified persons be required to carry cards to document the covered tasks for which they are qualified?
Carrying ID cards to document covered tasks that a person is qualified to perform is permissible but not required. Some means is needed to allow a supervisor or foreman to determine the covered tasks for which persons under his/her supervision are qualified. The issuance and possession of ID cards is one means by which a supervisor or foreman can make this determination. Other means could include an electronic database accessible to the appropriate personnel that contains qualification records of all persons qualified to perform covered tasks for the operator. Paper (“hardcopy”) records may also be appropriate.
Positive identification of the individual performing the covered task may also be required in cases where the individual and his or her qualifications are unknown to the job supervisor. The operator should require a government-issued identification in order to confirm that the correct individual has reported to the job site for the performance of the covered task.
3.2 How should operators document the covered tasks for which a person has been qualified?
Operators should have some means in place to make sure that field supervisors can verify that individuals are currently qualified for the tasks that they are performing. Some means is needed to allow a supervisor or foreman to determine the covered tasks for which persons under his/her supervision are qualified. FAQ #3.1 discusses some of these methods.