On December 7, 2009 the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a pipeline safety Advisory Bulletin informing operators about the standardized notification process for operator qualification (OQ) plan transmittal from the operator to PHMSA. This Advisory Bulletin also informs operators about PHMSA’s definition of “Observation of on-the-job performance” as applicable to determining employee qualification and “Significant” as applicable to OQ program modifications requiring notification. Finally, it makes other miscellaneous clarifications to assist operators in complying with OQ program requirements.

Operators using observation of on-the-job as a means of evaluating employee qualification should be aware that PHMSA advises that:

1. Observation without interaction during on-the-job performance does not provide an adequate measurement of the knowledge and skills of the individual;
2. There are no covered tasks where observation of on-the-job performance is adequate as the sole method of qualification; and
3. Observation of on-the-job performance does not measure the individual’s ability to recognize and react to abnormal operation conditions (AOCs).

This advisory is consistent with how APGA Security and Integrity Foundation (SIF) has always used observation as an evaluation tool. SIF evaluations have always included written or oral tests for knowledge and abnormal operating conditions in addition to hands on demonstrations of skills and abilities.

PHMSA also provided guidance on what it considers “significant” changes to written OQ plans gram modifications that would trigger the requirement to send notifications of significant modification of an OQ Program to the OPS Information Resource Manager. Significant includes but is not limited to: increasing evaluation intervals, increasing span of control ratios, eliminating covered tasks, mergers and/or acquisition changes, evaluation method changes such as written vs. observation, and wholesale changes made to OQ plan.”

A copy of the advisory can be downloaded here. For further information contact John Erickson, APGA Vice President, Operations (202-464-2742, ext 1002 or jerickson@apga.org).