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FREQUENTLY ASKED QUESTIONS

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FREQUENTLY ASKED QUESTIONS

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GENERAL
1. When was the OQ Integrity Process (OQIP) established?

Led by the Distribution Contractors Association (DCA), the coalition was established in 2016.

2. What was the driver behind the OQIP?

The current minimum OQ regulatory requirements and the lack of a specific industry OQ standard have created redundant, and often inconsistent, qualification expectations within the gas utility industry. The primary goal of the OQIP is to increase the integrity, consistency, quality, and reliability of the core competency aspect of each qualification, while recognizing the need for each operator to ensure workers are qualified according to their specific needs and requirements.

3. Why was the OQIP established?

To raise the bar for operator qualification by establishing an elevated level of common OQ practices and increase consistency between programs.

4. How is the OQIP document structured?

The OQIP is divided in to three primary sections: People, Process, and Program Validation (i.e., audits).

5. Describe OQIP benefits for the key stakeholders?
Operators:
• Consistency between OQ programs for contractor core qualifications
• Ability to increase focus on operator specific OQ requirements for contractors
• Predictable expectations when audited by state inspectors
• Mutual Aid / Mutual Assistance
Contractors:
• Predictable OQ expectations when engaging with new operators
• Reduction in redundant qualification requirements for core skills
Regulators:
• Consistency between OQ programs
• Validated contractor qualification requirements
• Program audit and program effectiveness measures
OQ Service Providers:
• Increased understanding and delivery of expectations for OQ programs
• Ability to focus on increasing quality of core OQ programs
Customers/Field Workers:
• Safer work environment
• Quality training and assessment processes
6. Why has OQ portability been so difficult to achieve to date?

The initial OQ Rule in 49 CFR 192, Subpart N, lacked specificity. As such, there was an early divergence in program expectations, requirements, and associated processes. Prior to the OQIP, portability efforts focused on achieving 100% portability of an OQ record without regard to operator specific requirements that must be addressed.

7. Tell us about the OQIP pilots.

The OQIP Coalition members have focused on holding three (3) proof-of-concept pilot programs across the United States. The initial OQIP pilot program participants include New Mexico Gas Company of Albuquerque, NM, Puget Sound Energy of Bellevue, WA, and SEMCO Energy Gas Company of Port Huron, MI. Click here to learn more about the OQIP Pilot Programs.

8. Do you think the OQIP document will/should get adopted by ASME? Would that benefit the initiative?

The OQIP has collaborated with individual members of the ASME B31Q Technical Committee and other industry stakeholders to develop a consensus on elements incorporated in the OQ Integrity Process. Questions regarding the adoption or incorporation of the OQIP into industry standards and recommended practices should be directed to those organizations. However, unified efforts to develop and adopt model programs and standards in the industry does benefit all stakeholders.

9. How will the OQIP address the regional OQ differences & varying State Regulatory Requirements?

There is a realization that the OQIP may not work the same way for all regions. Each region will move forward as they can and in alignment with their State Regulatory Agency. The purpose of OQIP is to raise the integrity, validity, and credibility associated with the delivery of operator qualifications to industry personnel, and this remains consistent with the attitudes and trends of the various State agencies. It is the desire of the OQIP to see a convergence of consistent requirements throughout the industry as model programs and standards mature.

10. What do you think the effects will be (good/bad/any?) from the New York State Department of Public Service OQ White Paper?

The NY White Paper has raised the level of discussion and engagement around many of the issues which the OQIP seeks to address. The regulatory impact of the NY White Paper is yet to be realized, however, the NY White Paper and the OQIP both align in recognition of the need for a model program with increased expectations that exceed the current minimum Federal OQ regulations.

11. What is the incentive for an operator to change their OQ program if their regulator is okay with their current plan?

Each operator is different in their needs and the maturity of their programs, however, the OQIP can bring additional benefits of consistency between OQ programs for contractor core qualifications, the ability to increase resource focus on operator specific OQ requirements for contractors, more predictable expectations when audited by state inspectors, and mutual aid benefits. Overall, increasing integrity and program effectiveness is a matter of continuous improvement for all organization in the industry.

12. PSMS (API RP 1173) seems to be taking off. Does it compete with, or enhance, OQIP?

PSMS and OQIP are mutually beneficial as both are premised on a continuous improvement process. The OQIP Coalition has heard some operators report they are leveraging their OQ Program as part of their PSMS implementation.

13. Who will manage the OQIP database? Cybersecurity concerns?

OQ records will be retained by the entity that originates the original record (operator or third-party service provider). The OQIP (and Governance thereof) will only house a unique ID generator for entities and individuals participating in the OQ Integrity Process. A small sub-team of the OQIP Coalition is working to develop a secure and consistent process for the transfer of universal records on core qualifications between participating entities.

14. Question: What do you perceive will be the biggest challenge to implementing the increased expectations of the OQIP?

Leadership and behavioral changes. Just as with the topic of Pipeline Safety Management Systems (PSMS) and the critical importance of executive support for an effective safety culture, those same elements must be addressed for the OQIP. The OQIP is not a mandatory process. While it may appear easier to stay with the status quo and only comply with the minimum regulatory requirements, it is the position of the OQIP that as an industry we must be proactive and move to voluntarily raise the bar on operator qualification.

15. How do I get my company involved?

Click here to express your interest in the OQ Integrity Process.

16. How do I sign up for any OQIP document news and information?

Click here to sign up for OQIP news and information.

17. Who will be managing this document going forward?

The OQIP Coalition membership, in conjunction with the formation of a formal OQIP Governance program, as outlined in the OQIP website.

PEOPLE
1. What positions are covered in OQIP?

Trainer, Proctor, Evaluator, and Auditors

2. How did the OQIP Coalition decide on the KSA requirements for the positions identified in the above question?

The OQIP Coalition membership researched industry best practices and reached these requirements by consensus (see list of membership).

3. What are some of the key elements of the OQIP People section?
• Credentialed trainers and evaluators
• Mandatory requirements to proctor any tests
• Trainer and evaluator prerequisites to include a combination of education, training, and field experience
• Trainers and evaluators must maintain and refresh their credentials
• OQ programs are subject to audits and program effectiveness reviews
4. What is the OQIP Coalition’s view on mandating the use of third-party proctors and evaluators?

The OQIP does not mandate the use of third-party proctors and evaluators. It does, however, require the use of properly trained and credentialed proctors and evaluators in accordance with the OQIP document.

The decision to rely on internal or third-party personnel is an operator specific decision. Company employees have served in roles for QA/QC, Audits, Inspections, etc. and have frequently held prominent roles in managing quality for their company and within the energy industry.

5. If company employees continue to have a role in ensuring quality work is being performed in the field, what are the assurances that they are doing their job correctly?

Through the performance and adherence of the OQIP process document which includes requirements for internal audits and independent audits.

The Independent Auditor requirements of OQIP provides additional oversight to ensure companies are operating with integrity and in a manner consistent with the OQIP requirements.

6. Should an evaluator be a qualified individual (QI)?

Evaluators are not required to be operator qualified as OQ is currently defined in 49 CFR 192, Subpart N. However, evaluators must be vetted and able to substantiate and demonstrate the experience, knowledge, skill, and abilities necessary to conduct evaluations effectively and accurately through observation. Notwithstanding the foregoing, nothing precludes an operator or contractor from requiring the evaluator to qualify for tasks they evaluate.

7. Could this result in the lowering of the bar for qualified individuals (QI)?

No. On the contrary, it raises the bar for all participants involved in the OQ process. The current OQ Rule does not provide for any specific credentialing requirements for evaluators, however, the OQIP does set credentialing requirements. Adhering to OQIP requirements will improve consistency between evaluators. The OQIP creates separate and distinct requirements between a qualified individual, instructor, proctor, and evaluator.

8. Given the importance of the evaluator – it is often called the lynchpin to OQ- how do we ensure that the training is hitting the mark?

The OQIP provides specific requirements for Program Effectiveness Reviews to ensure that programs and related processes, including training, are achieving the desired results for safety, competency, and quality. More information on this element can be found in the Program Validation section of the OQIP.

9. How did the OQIP decide on the experience requirements for someone to be a trainer or an evaluator?

The OQIP Coalition reviewed academic and industry norms for credentialing personnel on technical and administrative activities. Extensive discussions took place within the OQIP Coalition. In the end, multiple options were agreed and decided on. The goal was to provide flexibility in the path to conformance to recognize the diverse variations of education, skill, and experience that might be brought to bear during the credentialing process.

PROCESS
1. Question: Why does the OQIP set additional expectations that go beyond what the Federal Regulations already mandate Operator Qualification requirements?

The Federal Regulations established a minimum requirement for the qualification of pipeline personnel. Over the years, PHMSA has recognized deficiencies in the current regulation and has attempted to expand the scope of the requirements. For a variety of reasons, these efforts have been unsuccessful or incomplete. However, during these regulatory processes numerous individual operators and trade groups acknowledged the need to increase the standard at which the industry operates. The OQ Integrity Process embraces many of these topics, but in a manner that is driven by the industry and not through regulation.

2. Question: Why is the OQIP based on the ASME B31Q Standard for Pipeline Personnel Qualification?

The ASME B31Q represents over 15 years of industry-level work to establish a consensus on the identification and definition of tasks, and the core competency requirements for each task. The ASME is the collective work of operators, contractors, regulators, consultants, service providers, subject matter experts, and other stakeholders across multiple industry segments.

3. Question: Is the OQIP only for gas distribution companies?

No. All companies and industry segments can benefit from the OQIP. By adopting the ASME B31Q, common tasks have been identified and defined for operations involving natural gas, hazardous liquids, gas distribution, transmission pipelines, and other facilities.

4. Question: Can an operator use a task list other than the B31Q?

The OQ Integrity Process was designed and intended to be used based on industry standards to promote the consistency and the transferability of certain portions of a qualification record. As such, the principles, and processes for the OQIP can be effectively applied to any program. However, the OQIP was specifically developed with the intent for participating operators to utilize the B31Q to promote consistency in the industry.

5. Question: Are all tasks in the B31Q covered in the OQIP?

Yes. In the original draft of the OQIP, the team identified 65 tasks that were most performed by contractors. However, as interest in the OQIP has grown with multiple stakeholders and across multiple industry segments, the OQIP was expanded to cover all tasks identified by the ASME B31Q.

6. Question: Does the B31Q already address administrative processes for the qualification of pipeline personnel?

The ASME B31Q provides an industry level standard for identifying tasks and core competency requirements. It also provides guidance, structure, and considerations for processes without setting specific requirements for the administration of a qualification program. One of the goals of the OQIP is to establish consistent expectations for some of the specific administrative aspects of how the industry qualifies workers. The OQIP relies on a layered model, with each layer providing support to the other. The OQIP adopts the B31Q standards and guidance and then outlines specific minimum administrative processes regarding the delivery of training, testing, evaluations, and other related processes.

7. Question: Can an operator customize the OQIP process for their specific needs?

Yes. The OQIP is designed with the intent that each operator will require additional operator-specific training or assessments in addition to the core competency requirements.

8. Question: Does the OQIP replace an operator’s OQ Plan or program?

No. The OQIP does not replace the operator’s OQ Plan or program. Each operator is required to establish a written OQ Plan in accordance with state and federal laws. The OQIP establishes recommended practices to increase the integrity and effectiveness of the operator’s overall OQ program.

9. Question: Does the OQIP establish a mandated standard for learning content development?

No. The OQIP requires that training material be developed using industry-recognized practices and processes for the identification of learning objectives and the development of training content. As such, the OQIP recommends that content be developed utilizing recognized methodologies, such as those established by IACET (International Association for Continuing Education and Training), ANSI (American National Standards Institute), Association for Talent Development (ATD), or similar industry recognized and accredited programs intended for the development of training and educational content.

10. Question: What is the goal of the OQIP?

The goal of the OQIP is two-fold: (1) Increase the quality and integrity of the OQ process in order to meet operator and regulatory expectations, and (2) decrease redundancy in qualification processes so that contractors may leverage valid qualifications with multiple operators. To achieve these goals, all stakeholders must have trust and confidence in the quality and integrity of each qualification record.

11. Question: What is meant by ‘core competencies’ or ‘core’ OQ records?

The OQIP addresses the topic of technical competencies in two parts; the portion of an activity or task wherein the knowledge skill and ability to perform that task should be universally true for all workers (the core competency), and the portion that may require additional knowledge, skill, and ability based on the equipment utilized, the environment where the task is performed, or the policy and procedures established by an operator.

12. Question: Is transferability the same thing as portability of qualification records?

Yes, but not in the manner that it has been traditionally defined in the industry. Traditional use of the word portability has meant an all-inclusive sharing of a complete qualification record, which may or may not fully align with an operator’s specific requirements. Under the OQIP, it is only the qualification of the core competency record that is transferrable. An operator must also ensure that a contractor or other worker meets the additional operator-specific qualification requirements.

13. Question: How will transferability of OQ records be achieved with the OQIP?

By establishing an increased industry expectation for both the content and the processes involved in a qualification record, the quality and integrity of the qualification records for core competencies can be established and recognized by operators. These competencies align with industry-standard processes as outlined by the ASME B31Q. The content providers, operators and contractors participating in the OQIP each voluntarily agree to develop content and administer their programs in a manner that is compliant with the expectations of the OQIP.

14. Question: Is the use of foreign language content allowed by the OQIP?

The OQIP leaves the decision on allowable language alternatives to each company based on the needs and demographics of their organization. However, all qualifications must provide evidence of the individual’s knowledge, skill, and ability to perform the designated task accurately and safely, which includes the clear and accurate communication of information.

15. Question: How are Abnormal Operating Conditions (AOCs) addressed in the OQIP?

The OQIP requires each content provider to identify, develop, and include appropriate AOC’s in their content and programs. Since AOC requirements and expectations may vary, the OQIP states that it is the responsibility of the operator to ensure any unique or specific AOC requirements and reaction protocols (for generic AOC’s or task-specific AOC’s) are included in the operator specific portion of a worker’s qualification.

PROGRAM VALIDATION
1. Are the OQIP Program Validation expectations required by regulation?

No, it is not required by regulation; however, to raise the bar and provide a common program that might be accepted at an industry level, the OQIP has incorporated audit and Program Effectiveness reviews.

2. Will a standard audit document be utilized for the validation process, or is each organization responsible for its own?

The OQIP Coalition has drafted a standardized audit document template as part of the OQIP that can be customized to meet each organization’s needs.

3. How will each person conducting the audit be able to identify whether an organization, either internally or independently audited, meets the identified expectations?

The OQIP Coalition has drafted a standardized audit document. Evidence of conformance is outlined in the OQIP audit template.

4. For organizations utilizing this OQIP process, there are expectations to have audits conducted to identify gaps, strengths, and weaknesses. Who, or what entity can provide such independent audits of the processes?

Please refer to Section 7.4 and 7.5 of the OQIP document, which outlines specifications relating to audits and record keeping.

5. Will independent audit organizations be required to hold any credentials to audit the OQIP process?

Yes, independent auditors should hold credentials that evidence their knowledge and experience as an auditor in a manner consistent with acceptable industry practices, and they must acknowledge their understanding of the OQIP requirements and audit process.

6. Who will hold the records and findings of that audited organization, once completed?

The OQ service provider who is a member of the OQIP process will be charged with the responsibility to house the findings of their customer (OQIP user), and to address any potential actions necessary to bring their OQIP customer into compliance with the OQIP requirements.

7. How will organizations who choose to adopt the OQIP process know who they can use in the role of trainer, proctor, performance evaluator, or auditor?

It is the intent of the OQIP Coalition to maintain and provide access to a list of participating organizations and credentialed participants.

8. Is this document required by regulation?

No, it is not required by regulation; however, to raise the bar and provide a common program acceptable to many we added Program Effectiveness reviews.

9. Unless operators adopt the same SOPs, is it possible for this process to be a 100% portable?

The OQIP is not intended to be 100% portable. The foundation of the portability concept in the OQIP is an ‘80/20 rule’. Under this concept, the core competencies and universally true aspects of qualifications for a task (say, 80% of a qualification) become portable, and the unique requirements of an operator (say, 20%) are not portable due to their specific alignment to the operator’s O&M and SOPs.

The primary goal of the OQIP is to bring integrity, consistency, and quality to the core competency aspect of each qualification, while recognizing the need for each operator to ensure workers are also qualified according to their specific needs and requirements.

10. Does the OQIP set guidelines that will have operators maintaining two different systems to track OQ qualifications?

No, although an operator may choose to manage OQ records in that format. The intent is to have a standardized process and documents that will be the same for everyone and integrate both the core competency qualification and the operator specific qualification for a qualified individual in the same OQ record for that specific operator.

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The OQ Integrity Process is not intended to be the basis of future regulation. While increasing consistency and standardization will result in “raising the bar” by going above and beyond current regulation, this will be achieved by voluntary actions overseen by Process participants.
The OQ Integrity Process is not intended to be the basis of future regulation. While increasing consistency and standardization will result in “raising the bar” by going above and beyond current regulation, this will be achieved by voluntary actions overseen by Process participants.