OQIP History
Established Testing and Qualification of Pipeline Employees
The United States Department of Transportation (DOT) Pipeline and Hazardous Materials Administration (PHMSA) published the Qualification of Pipeline Personnel Rule, commonly referred to as the OQ Rule, which provided direction on the testing and qualification of pipeline employees.
The OQ Rule proved to be effective in advancing the evaluation of pipeline employees. However, the original requirements were not very prescriptive, and so pipeline operators, contractors, and OQ providers had to develop individual programs that met the intent of the OQ Rule. With the Rule being open to broad interpretations, operators’ programs were tailored to their unique operating conditions and environments, including variances in key areas such as covered task lists and the qualification of individuals. Pipeline operators were held responsible for compliance with the OQ Rule, so they often insisted that contractors who work on their pipeline, meet their strict requirements, without exception.
In 2016, the Distribution Contractors Association (DCA) established a task force to investigate whether and how the industry can improve the OQ process and provide more consistency in compliance with operator OQ programs. Recognizing pending adjustments by PHMSA to several provisions of the OQ rule, the task force believed a fresh look at and potential new approaches to OQ will benefit all stakeholders.
The Bar Raised Higher
The work of the task force has evolved from a discussion of several OQ-related issues by an ad hoc group of interested stakeholders to a structured and chartered coalition consisting of DCA contractors, OQ service providers, Gas Operators, Regional and National Gas Associations, Industry consulting groups, & subject matter experts who represent various sectors of the Gas Industry from all areas of the nation. Staff from DCA and the American Gas Association also are supporting this effort. This group evolved and built a strong, Industry Coalition on OQ Integrity, establishing high expectations and placing validating measures in place to assure member organizations are performing with “the bar raised higher” than we have often seen in our industry. The efforts of these members of the OQIP Coalition have created a fundamentally different, yet sound and robust process that creates a standardized approach to deploying all aspects of qualifying, training, testing, and auditing elements associated with OQ. The deliverables of this OQIP process lays out specific expectations and benchmarks for all who choose to strive for OQ excellence, and are willing to be audited and held accountable for operating at a higher level of OQ program effectiveness, auditing, and leading the American Gas Industry in safe, reliable, validating, and credible Pipeline Personnel Qualifications.
Consistent and Standardized OQ Process by Voluntary Actions
The OQ Integrity Coalition realized that while a fully consistent and standardized OQ process was not a realistic goal, given the uniqueness and specific requirements of each Operator, there is a strong belief that utilizing consistent approaches to qualify individuals regarding a large majority of common core competencies was realistic, with the understanding there will be certain OQ requirements held by pipeline operators that are appropriate to their unique systems. Therefore, the “end goal” established by the Coalition was to develop and promote a more consistent and standardized OQ process. This will understandably derive several positive results associated with credibility and validity to the individual pipeline worker’s OQ credentials they obtain.
The OQ Integrity Program 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 Program participants. Operators should not be penalized in the future for exceeding regulatory compliance in the spirit of improving the effectiveness of their OQ programs.
As the Program develops, participants may find value in conducting gap analyses of their OQ programs. A gap analysis will enable a participant to compare the effectiveness of its current OQ program to its potential effectiveness under the elements provided in the OQ Integrity Program.
TESTING & QUALIFICATIONS
Established Testing and Qualification of Pipeline Employees
The United States Department of Transportation (DOT) Pipeline and Hazardous Materials Administration (PHMSA) published the Qualification of Pipeline Personnel Rule, commonly referred to as the OQ Rule, which provided direction on the testing and qualification of pipeline employees.
The OQ Rule proved to be effective in advancing the evaluation of pipeline employees. However, the original requirements were not very prescriptive, and so pipeline operators, contractors, and OQ providers had to develop individual programs that met the intent of the OQ Rule. With the Rule being open to broad interpretations, operators’ programs were tailored to their unique operating conditions and environments, including variances in key areas such as covered task lists and the qualification of individuals. Pipeline operators were held responsible for compliance with the OQ Rule, so they often insisted that contractors who work on their pipeline, meet their strict requirements, without exception.
In 2016, the Distribution Contractors Association (DCA) established a task force to investigate whether and how the industry can improve the OQ process and provide more consistency in compliance with operator OQ programs. Recognizing pending adjustments by PHMSA to several provisions of the OQ rule, the task force believed a fresh look at and potential new approaches to OQ will benefit all stakeholders.
RAISING THE BAR
The Bar Raised Higher
The work of the task force has evolved from a discussion of several OQ-related issues by an ad hoc group of interested stakeholders to a structured and chartered coalition consisting of DCA contractors, OQ service providers, Gas Operators, Regional and National Gas Associations, Industry consulting groups, & subject matter experts who represent various sectors of the Gas Industry from all areas of the nation. Staff from DCA and the American Gas Association also are supporting this effort. This group evolved and built a strong, Industry Coalition on OQ Integrity, establishing high expectations and placing validating measures in place to assure member organizations are performing with “the bar raised higher” than we have often seen in our industry. The efforts of these members of the OQIP Coalition have created a fundamentally different, yet sound and robust process that creates a standardized approach to deploying all aspects of qualifying, training, testing, and auditing elements associated with OQ. The deliverables of this OQIP process lays out specific expectations and benchmarks for all who choose to strive for OQ excellence, and are willing to be audited and held accountable for operating at a higher level of OQ program effectiveness, auditing, and leading the American Gas Industry in safe, reliable, validating, and credible Pipeline Personnel Qualifications.
VOLUNTARY ACTIONS
Consistent and Standardized OQ Process by Voluntary Actions
The OQ Integrity Coalition realized that while a fully consistent and standardized OQ process was not a realistic goal, given the uniqueness and specific requirements of each Operator, there is a strong belief that utilizing consistent approaches to qualify individuals regarding a large majority of common core competencies was realistic, with the understanding there will be certain OQ requirements held by pipeline operators that are appropriate to their unique systems. Therefore, the “end goal” established by the Coalition was to develop and promote a more consistent and standardized OQ process. This will understandably derive several positive results associated with credibility and validity to the individual pipeline worker’s OQ credentials they obtain.
The OQ Integrity Program 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 Program participants. Operators should not be penalized in the future for exceeding regulatory compliance in the spirit of improving the effectiveness of their OQ programs.
As the Program develops, participants may find value in conducting gap analyses of their OQ programs. A gap analysis will enable a participant to compare the effectiveness of its current OQ program to its potential effectiveness under the elements provided in the OQ Integrity Program.