Top OQ Issues to Date
Office of Pipeline Safety
Slide 1
Top OQ Issues to Date
- Written Program
- Operators did not have a written program when inspected
- The written program was in place after 4/27/01 (or) operators were not following the requirements of their written program
Slide 2
Top OQ Issues to Date
- Abnormal Operating Conditions
- AOCs were not identified
- AOC recognition & reaction were not part of qualification process (or)
- AOC reactions were not specified for the identified AOCs
Slide 3
Top OQ Issues to Date
- Contractor Qualification
- Inadequate processes in written program for handling contractor qualifications
- Contractor qualifications not reviewed
- Contractors performed covered tasks without being qualified (or)
- Contractors qualified by WPHR
Slide 4
Top OQ Issues to Date
- Field Implementation of OQ Program Requirements (Protocol 9)
- Individuals not qualified to perform covered tasks
- Inadequate O&M procedures
- Qualifications do not match procedures
Slide 5
Top OQ Issues to Date
- Field Implementation of OQ Program Requirements (Protocol 9) (Cont’d)
- Individuals not familiar with equipment used to perform covered task
- Poor gas practices, and
- Use of unapproved equipment
Slide 6
Top OQ Issues to Date
- Records
- Inadequate
- Incomplete
- Incorrect (or)
- Non-existent qualification records
Slide 7
Top OQ Issues to Date
- Evaluation Methods
- Evaluation methods inadequate to measure knowledge and skills for covered tasks
- Evaluation process employed questionable practices (or)
Slide 8
Top OQ Issues to Date
- Evaluation Methods (Cont'd)
- Evaluation processes were unacceptable
- Performed own evaluation
- Regarded examinations upon post-test
review
Slide 9
Top OQ Issues to Date
- Work Performance History Review (WPHR)
- Inadequate/no supporting documentation for WPHR qualification decision
- Individuals qualified solely by WPHR after 10/26/99 (or)
Slide 10
Top OQ Issues to Date
- Work Performance History Review (WPHR) (Cont'd)
- No qualification on AOCs if WPHR used as sole method
Slide 11
Top OQ Issues to Date
- Covered Task List
- No documentation of CT list development
- Tasks required by regulations missing from CT list (or)
- Excavation activities not addressed in CTs
Slide 12
Top OQ Issues to Date
- Management of Change
- Not addressed in written program at all
- Insufficient detail/inadequate description of process
- Contractor communications not addressed (or)
- Changes that trigger requalification not identified
Slide 13
Top OQ Issues to Date
- Reevaluation Intervals
- Not addressed in written program (or)
- Intervals of 7 to 10 years used without justification
Slide 14
Top OQ Issues to Date
- Training
- Not addressed in written programs
Slide 15
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