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BPXA DOT Operator Qualification PlanOverview

May 2009

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At the end of the training the student will be able to:

Area ManagerIdentify their accountability for ensuring the Team Leads comply with the training and qualification requirements.Operations & Maintenance Team LeaderSection 2, 3Identify their responsibility for training and qualification of technicians completing covered tasks.Illustrate proper use of TRACCESS qualification reports.Illustrate proper use of ISNetworld qualification reports.Determine that a Performance Verification form has been properly completed.Section 5Interpret requirements of suspension of qualification on covered tasks during an incident/accident.Interpret requirements of suspension of qualification on covered tasks for criteria other than incident/accident.Explain criteria for returning to qualified status.Interpret requirements shown in Appendix A - Covered Task List.Illustrate proper use of TRACCESS qualification reports.Explain qualification tasks that Evaluators are authorized to complete.Interpret Evaluator qualification criteria.Section 6Illustrate proper use of ISNetworld qualification reports (contractors)Section 7Identify MOC requirements to OQ Plan changesSection 8Conclude that a Performance Verification form has been properly completed.Explain required documentation requirements.Illustrate proper use of TRACCESS qualification reports.Section 9Explain the requirement for participation in analysis of feedback for use in continuous improvement to the Plan.EvaluatorSection 5Explain the requirement of notifying supervision of a failed evaluation.Explain qualification tasks that Evaluators are authorized to completeIdentify Evaluator qualification data needed by the Evaluator’s supervisor.Conclude that a Performance Verification form has been properly completed.

Course Objectives

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OQ Rule

Required by: 49 CFR 192 for Natural Gas pipelines (Subpart N) 49 CFR 195 for Oil and NGL pipelines. (Subpart G)

BPXA’s Operator Qualification program is designed to ensure that individuals working on regulated pipeline facilities are qualified to perform specific “covered tasks” and to reduce the probability and consequences of incidents/accidents.

The OQ Plan applies to BPXA employees, contractors, sub-contractors and any other entity performing a DOT “covered task” as defined in this plan on behalf of BPXA on a DOT jurisdictional pipeline facility.

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BPXA OQ Responsibility OverviewIn serial form

The following slides demonstrate a typical series of actions that support the management of OQ qualifications for BP employees.

Contractor considerations will be handled toward the end of the presentation.

These slides are not a comprehensive review and do not take the place of full study of the entire OQ Plan.

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First Step: Learn About Your DOT OQ Plan

Attend a class or read study guides – such as this presentation.

Study/Read the BPXA DOT OQ Plan Ask Questions

OQ at BPXA

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Next Steps:Supervisor Pre-work

1. Determine what covered tasks are performed at your facility

2. Determine who will perform those covered tasks

OQ

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Supervisor Pre-work 1) Determine what covered tasks are performed at your facility:

OQ

Determining covered tasks applicable to your facilities can be ascertained from the Covered Task List.

From the Alaska Intranet site, select the DOT/Regulated Pipelines Programs link on the tech & hse directorate tab.

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Supervisor Pre-work 1) Determine what covered tasks are performed at your facility: Continued

OQ

At the pipeline site, select the link for Appendix A – Covered Task List/Index

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Supervisor Pre-work 1) Determine what covered tasks are performed at your facility: Review Covered Task List to determine which are applicable to your location

OQ

Titles of covered tasks are usually enough information to determine if they are done at your facilities.

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Supervisor Pre-work 1) Determine what covered tasks are performed at your facility: If task title doesn’t define the task for you, look at the covered task description available in Appendix B Covered Task Performance Verification Checklists. To get to Appendix B:

At the pipeline site, select the link for Appendix B – DOT Covered Tasks

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Supervisor Pre-work 1) Determine what covered tasks are performed at your facility: Appendix B Covered Task Performance Verification Checklists.

As an example, click on Covered Task 25

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Supervisor Pre-work 1) Determine what covered tasks are performed at your facility: Example Covered Task Performance Verification Checklist

OQ

The Description section of the Performance Verification Checklist gives you more detail about the task.

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Supervisor Pre-work 1) Determine what covered tasks are performed at your facility: Example Covered Task Performance Verification Checklist (continued)

These Process Steps give a lot of detail on what is involved in performing the covered task.

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Supervisor Pre-work 2) Determine who will perform those covered tasks

OQ1. Meet with appropriate personnel and determine who you expect to perform the covered tasks at your facilities.

2. List who and what tasks they are expected to perform. Some considerations: 1. The task is congruent with the individual’s discipline knowledge and skill. 2. If a task is not performed very often, consider how you can maintain proficiency in the

task – possibly limiting the number of individuals assigned to perform that task. 3. Do you want redundant coverage to help ensure that an OQ qualified individual is

always available or is it a task that has scheduling flexibility?

3. Meet with the individuals that are to perform the covered tasks you have listed for them and explain your expectations:

1. They are to be OQ qualified to the listed tasks2. They will only perform covered tasks for which they are OQ qualified3. They are to maintain currency in their OQ qualifications

4. Ascertain whether they have training as appropriate for each task – if not, provide more training which may include on-the-job training, lab simulation, or other technical training.

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Supervisor TRACCESS Assignments

OQ

After determining who does what covered tasks, make covered task and AOC training assignments in TRACCESS.

Note: No Covered Tasks can be performed without current AOC training documentation.

For more information on TRACCESS contact:

Kris Ingersoll 907-564-4252 or 659-5722

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Supervisor ResponsibilitiesSome questions to ponder about OQ:

OQ

Do I know what DOT OQ covered tasks are performed in my area?

Do I know who performs the DOT OQ covered tasks in my area?

Do I know how to make reports in TRACCESS or read monthly compliance reports?

Are my employees assigned the correct OQ qualification tasks in TRACCESS?

How often do I review the qualification assignments in TRACCESS?

How often do I review the TRACCESS qualification assignments with my employees?

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Supervisor ResponsibilitiesMore questions to ponder:

Are my employees reported as Complete in TRACCESS for the covered tasks they perform?

Do I ensure that AOC training is Complete in TRACCESS before assigning any DOT OQ covered task?

Have I read and understood the BPXA DOT Operator Qualification Plan?

Do I ensure that my employees, who perform OQ covered tasks, have read and understand the BPXA DOT Operator Qualification Plan?

Do I provide the appropriate training for the tasks that my employees perform? This also includes such things as changes to equipment, AOCs, codes, or procedures.

Do I ensure that employees are provided appropriate communication about changes and new information such as organizational changes, lessons learned, root causes, or audits?

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Covered Task Performer Actions

Now that your supervisor has assigned AOC training, other applicable pre-requisites (if any), and OQ tasks in TRACCESS, review your status for each of the practical and knowledge elements.

Notes: The monthly DOT Training Report can also be used to determine status. This report is available at all locations.

A separate presentation is available on how to read the monthly report.

A separate presentation is available on how to generate customized reports in TRACCESS.

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Covered Task Performer Actions(continued)

If the status is Incomplete for any of the assignments:

Have you completed your BPXA Abnormal Operation Conditions training? This is available in TRACCESS and successful completion must be documented in TRACCESS, and is a pre-requisite to PVs.

Do you have appropriate training to perform this task? If not, discuss with your supervisor to determine how your knowledge and skill needs can be supported.

If your task training needs are met and you have documented completion of AOC training or any other pre-requisites identified in TRACCESS, request that an Evaluator be scheduled to evaluate your knowledge and skills on a covered task. The Evaluator will need to prepare for the evaluation.

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Evaluator

The role of the Evaluator is critical in maintaining the integrity of the OQ program. The Evaluator makes the determination whether or not a candidate has properly followed and demonstrated the knowledge and skill requirements set in the Performance Verification checklist (PV). The Evaluator also helps verify that all prerequisites have been completed before evaluation.

The process and procedures must be followed closely in order to maintain internal and external program credibility.

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Evaluator – Preparing for an evaluation

Before you evaluate a Candidate on a covered task make sure you are an approved Evaluator for that task.

The Evaluator must be approved by their supervisor who uses selection criteria of:

technical knowledge industry experience interpersonal skills

Provide your supervisor information on how you meet the Evaluator criteria.

BPXA Evaluators are authorized to administer performance evaluations (includes knowledge testing).

Evaluators from outside BPXA can be approved by the BPXA DOT Pipeline Advisor.

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Evaluator – Preparing for an evaluation(continued)

Print out the current copy of the Performance Verification (PV) Checklist (from Appendix B) and:

Read the PV and become familiar with the scope of the covered task Understand how to recognize and react to the task specific AOCs listed

in the PV Review the Reference Material list and ensure that the reference

material related to your location is available Review the Knowledge Assessment and the answer key – become

conversant in the answers and how they apply to your location Review the Process Steps and understand the flow of the task so that

you are prepared to decide whether the candidate has demonstrated how to correctly and safely perform the covered task.

Note: The PV does not take the place of a maintenance or operations procedure.

Note: It is recommended that you print out a new PV, from Appendix B, on the day of the evaluation – do not use a PV that has been stored elsewhere. Only the latest version of a PV is acceptable and older versions will be rejected.

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Evaluator and Candidate Meeting

An important part of the evaluation is to set an environment that allows the Candidate to perform at their normal level – with expectations understood and without undue stress. The demeanor should be “supportive” without providing coaching on the covered task performance.

To that end, it helps to meet with the candidate before the evaluation to explain the evaluation process, including to what resources the candidate has access. It is also a good time to verify that the candidate has documented completion of all pre-requisites; options include:

Ask the Candidate to provide a printed copy of a TRACCESS, or monthly DOT Training Report showing completion status on assigned requirements related to the covered task being evaluated.

Directly review completion status in TRACCESS.

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Evaluator and Candidate Meeting(continued) General Evaluation Flow

The Evaluator will share with the Candidate any parts of the following general evaluation process flow as they see fit:

General Flow – page 1 of 3 Candidate verifies that they have completed all required OQ training

(pre-requisites) before requesting an evaluation. Candidate and Evaluator schedule time for the evaluation. Evaluator verifies that their supervisor approved them to be an

Evaluator for the task. The Evaluator or Candidate prints out the current Performance

Verification checklist from the OQ Plan or located in the Candidate’s TRACCESS folder.

Evaluator verifies that the Candidate has documented completion of the pre-requisites. (As discussed in previous slide.)

Evaluator explains to the Candidate what the evaluation will entail and will emphasize safety as the primary consideration during the evaluation process.

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Evaluator and Candidate Meeting(continued) General Evaluation Flow

General Flow – page 2 of 3 During the evaluation the Evaluator must directly observe the

Candidate. The Evaluator must be close enough to the work being conducted and have no obstructions between the Candidate and the Evaluator that would impede the Evaluator’s ability to take immediate corrective action. The Evaluator must take immediate corrective action as necessary in the event that the Candidate performs, or starts to perform, the covered task incorrectly.

The Evaluator must not coach the Candidate during any part of the evaluation other than that specifically detailed on the Performance Verification checklist.

It is recommended that the the Knowledge Assessment portion of the evaluation be administered before doing the Performance evaluation.

Administer the Performance Evaluation Checklist portion of the evaluation.

Note: to more accurately evaluate skills, for initial qualification, it is preferred that actual demonstration of the task takes place. This is not possible in some situations – the next preferred method is simulation, and the least preferred method is oral evaluation.

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Evaluator and Candidate Meeting(continued) General Evaluation Flow

General Flow – page 3 of 3Complete all fields on the PV form. Make sure that the Evaluator and

Candidate sign and date the form immediately after the evaluation.

If any of the steps were not acceptable, the Candidate will not be qualified and will need to schedule a re-evaluation. Prior to the re-evaluation, it is required that the individual work with their supervisor or Operations/Maintenance Lead Techs for additional training as appropriate, which may include self-study, on-the-job review with qualified personnel or other documented options. At any time, the individual may request a different Evaluator.

Supervision will be notified of any non-successful attempts at qualification.

For successful evaluations, forward the signed Performance Verification checklist to the appropriate Team Lead or designee. The Team Lead is responsible that TRACCESS is updated with the qualification status and the hard copy of the PV filed.

Note: A separate job aid presentation is available for performing a quality check of a PV checklist before it is filed.

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Evaluation Day

Verify that it is safe and operationally prudent to perform the evaluation at the scheduled time. An evaluation does not negate any safety, operational, or procedural practice.

Re-schedule the evaluation when necessary to support a credible qualification process.

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Evaluation Day (continued)

Follow the general evaluation flow described in the previous slides.

It is important that documentation, in TRACCESS and hard copy, is properly completed and filed. Each location defines their filing process but must meet the retention requirements defined in the OQ Plan.

Missing or incomplete documentation = not OQ qualified.

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Contractor OQ Considerations

Most contractor OQ qualifications are reported and documented in ISNetworld.

There is a separate presentation available for viewing contractor qualifications in ISNetworld.

Most contractor OQ qualification evaluations are done by an approved third party provider.

There are only a few exceptions to this, such as contractors that are control room operators.

BPXA Managers/Supervisors are accountable for ensuring contractors are OQ qualified when performing covered tasks on their pipeline facilities.

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Task Performers: How do I know if I’m performing a covered task?

Rule of Thumb: If an operations or maintenance task is performed within the DOT jurisdictional area on the pipeline it is extremely likely you are performing a covered task.

To determine the DOT jurisdictional area of a pipeline look up the demarcation points described in the facility Operation, Maintenance, and Emergency Response (OMER) manual, and the facility Piping and Instrumentation Diagrams.

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How do I know which covered task is being performed?

If it is a DOT Preventative Maintenance work order many will have text that defines covered task qualification requirements.

If the equipment you are working on happens to be listed in Appendix B of the facility OMER you can look up, in CMMS, the PM work orders written for that tag Number. Many PM work orders with DOT in the title typically indicate there are covered tasks associated with it.

If the equipment/component isn’t listed in the OMER Appendix B, you will need to look at Appendix A & B in the BPXA OQ Plan to determine which task matches the equipment. See example on the next slide.

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Example – Work on a 1” drain valve on a DOT jurisdictional pipeline

Assumptions: The valve does not show up in OMER Appendix B; it is within DOT jurisdiction; there is no PM for the valve.You know you are working on a valve therefore you will look for clues on the covered task list that indicate they are valve related.

Use the guidance provided in earlier slides on how to access BPXA OQ Plan Appendix A & B.

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Example – Work on a 1” drain valve on a DOT jurisdictional pipeline (continued)

Appendix A shows that:•Task #19 relates to valve maintenance

•Task #20 relates to inspecting valves

•Task #21 relates to repairing valves.

The subtasks help further define the scope of the task. For example, if you are lubricating a valve that subtask is 19.2, thus you must be qualified to covered task 19.

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Contact Information

Have questions about OQ tasks?

GPB – GPB Compliance Coordinator 907.659.5806

ACT - Joni Johnson 907.659.8132