OQ Program Effectiveness Review – The Systemic Way

Purpose

Several years ago, PHMSA published a notice of proposed rulemaking (NPRM) that would have changed the OQ Rule in a number of ways – one of the proposed changes would have required pipeline operators to develop and implement a process to measure the program’s effectiveness. Ultimately, that NPRM was not adopted, but it made clear that measuring program effectiveness would be a goal of the regulator going forward. Today, we see similar program effectiveness requirements in standards such as API RP 1161 and ASME B31Q. Such a review would typically be done on an annual basis and the findings organized such that the operator can see performance trends over time. It is clear that the need for ongoing effectiveness measurement has become a reality for pipeline operators.

Our Approach

Systemic Compliance offers a unique approach to evaluating the effectiveness of your Operator Qualification (OQ) program. Our approach will help you better evaluate where you are, better clarify what adjustments should be made, and allow you to measure program effectiveness in a more objective and repeatable way, this helps ensure continuous improvement.

The program review will focus on the OQ program that has been created and implemented by the pipeline operator. The objectives of this review will be:

To evaluate whether the OQ program complies with the requirements of the DOT/PHMSA OQ Rule;
To evaluate whether the OQ program complies with additional requirements set forth by state agencies, as applicable;
To evaluate whether the written OQ program conforms to industry standards such as API RP 1161, ASME B31Q, DCA OQIP, etc.;
To evaluate whether the OQ program adequately addresses all requirements found within enforcement guidelines, and PHMSA FAQs;
To evaluate whether products and services of applicable 3^rd party service provider(s) adequately conform to the operator’s written OQ program;
To determine whether the OQ program is being implemented as documented;
To appraise the effectiveness of the OQ program; and
To provide recommendations and guidance to the operator in making appropriate program modifications.

Before work begins, we will work with the operator to customize and finalize these objectives such that the work is as relevant as possible to the operator’s specific situation. It may be that the operator does not have a need to align itself with one or more industry standards, for example.

The project will be completed in phases, as agreed to with the operator:

Phase 1: Compliance Appraisal

This phase is focused on looking at the written program (and associated documents) to determine whether it complies with the Rule, enforcement guidance, and applicable standards. This is a desktop exercise – meaning, the focus is on the documents. At the completion of this phase, we will submit a written report of preliminary findings and meet with the operator to discuss questions and appropriate adjustments prior to beginning the Program Implementation Appraisal (Phase 2).

Phase 2: Program Implementation Appraisal

This phase focuses on review of implementation practices and answers the question, “Are we doing what our written program says we’re doing?”. This phase will include interviews and review of records for a representative sample of qualified personnel (employees and contractors) – sample size to be determined depending on active work projects, time available, and to be fully at the discretion of the operator. During Phase 2, we will also review the processes employed by applicable 3^rd party service providers and the records and documentation they maintain.

Phase 3: Program Effectiveness Appraisal

During this phase, we will evaluate the operator’s approach to measuring/ensuring program effectiveness. Our goal here will be to help make sure there is an effective framework for capturing and evaluating key performance indicators (KPIs) and/or other metrics to ensure an objective, repeatable process for measuring program effectiveness. If an operator has not yet defined applicable KPIs/metrics, we will help (in the initial review) to design such a framework such that measurements can be evaluated in subsequent reviews and so that trends can be analyzed over time.

Phase 4: Close-Out

At the conclusion of Phase 3, a formal written report, with recommendations, will be provided to the operator. A close-out meeting will be held with the operator to discuss findings and recommendations. Systemic Compliance will make itself available to help the operator make program modifications following this review and will help ensure that all Management of Change (MOC) requirements are met in that process.

Contact Us

Contact us today for more information on this service and/or to request a proposal. We’re confident we can scale this approach to be a valuable and cost-effective program feature for ANY operator. Continuous improvement is a fundamental element of a smart system. An objective, repeatable process for assessing program effectiveness is critical to achieving continuous improvement.

COMPLIANCE SHOULD BE SYSTEMIC!