Operator Qualification (OQ) Services for Pipeline Operators
The OQ Rule requires each pipeline operator to develop a qualification program to address each of the following requirements:
- Identify covered tasks
- Ensure that individuals performing covered tasks are qualified
- Allow for non-qualified individuals to perform covered tasks under the direction/observation of a qualified individual
- Evaluate any individual whose performance of a covered task contributed to an incident or accident
- Evaluate an individual if there is reason to believe he/she is no longer qualified
- Communicate changes that affect covered tasks to individuals performing those tasks
- Identify re-evaluation intervals
- Maintain records to demonstrate compliance
Your qualification program must assure qualification of your own employees who perform covered tasks as well as the qualification of any other personnel performing covered tasks – including those working on behalf of a contractor or subcontractor.
Veriforce does not sell covered task lists, but as your OQ provider we offer a number of covered task list options that will help you develop or refine your OQ program.
Veriforce began working with OQ in 2001 when a major pipeline company requested help. We began with six overriding objectives. These continue to be our guiding principles today.
- Honor the operator’s OQ program. It is the operator who must define:
- covered tasks
- evaluation criteria
- other program requirements
- Establish a common process for administering operator programs
- Create economies of scale (cost savings) for our operator clients
- Create an effective vehicle for sharing information among operator clients
- Offer a turn-key solution to our operator clients
- Be prepared to represent our operator clients however and whenever necessary to help demonstrate compliance with the OQ Rule
First and foremost, Veriforce focuses on representing pipeline operators. We do not market OQ services to pipeline contractors – we communicate program requirements to contractors and provide a vehicle for them to meet those requirements.
Veriforce administers your OQ program – we do not have an OQ program of our own. Your personnel get qualified for your program – not for Veriforce.
We provide turnkey program administration services. Beyond training and testing, it’s not just a database. We offer a database combined with training and testing, integrated with full program implementation and oversight services.
Effectively complying with the OQ Rule means dealing with many separate elements. Veriforce not only manages each of these elements, we have developed an efficient process for making them work together effectively and efficiently, resulting in improved ability to demonstrate compliance, and cost savings for our operators, both individually and collectively through economies of scale.
We have developed detailed procedures for each of the elements of our system. These procedures have been cross-referenced to the OQ Rule and to current enforcement protocols. To learn more about how we keep our OQ compliance procedures up-to-date, call us at 800.426.1604.
Website/VeriSource – We post and maintain operator-specific requirements, covered task lists, evaluation criteria, and other documents at our website for each of our operator clients. Many of our clients also use our online database, VeriSource, to post specific documentation, training programs, and safety procedures, so that their contractors have easy access to those documents/resources.
Outbound Communication – We take responsibility for communicating program requirements to those who need to meet those requirements. We communicate as needed to your employees and contractors. Through the VeriSource notification process, we can document the date/time that communication was read by its intended recipient. We maintain an electronic log of all telephone-based communication and archive all related email or other electronic correspondence.
Inbound Communication – We field phone-based and email requests for information, assistance, and other questions/issues from employees and contractors. With personnel designated to field these requests, we can ensure a continuous, consistent message and approach to questions and the daily issues which arise. We also maintain an electronic log of all inbound telephone-based communication and archive all related email or other electronic correspondence.
Evaluators are required to successfully complete the Veriforce Evaluator Training program annually.
Qualified Personnel – There are certain circumstances where training must be successfully completed by an individual before an evaluation may take place. In our process, evaluators are responsible for determining whether such circumstances exist and, if the situation demands it, verifying that appropriate training requirements have been met prior to conducting the evaluation.
We have developed effective training resources for many different covered tasks. Typically, these resources have been designed to support structured on-the-job training (OJT), although we are always working to develop new web-based training resources as well.
Customized Training – We have worked with many of our clients to design and deploy customized training programs – sometimes for clients’ own employees and sometimes for contractors. We have developed and conducted a wide range of traditional, instructor-led, self-paced, and web-based training sessions.
We oversee the process of personnel evaluation using operator-defined covered tasks and the underlying evaluation criteria. Each candidate must be evaluated individually on their knowledge, skills and abilities relative to the evaluation criteria defined for each covered task.
Veriforce procedures require that candidates are evaluated by authorized evaluators who will determine whether a candidate is qualified. To ensure an effective evaluation, all Veriforce evaluators are technically competent and subject matter experts (SME) in the specific task area.
We also help our clients locate authorized evaluators to evaluate and qualify their personnel. To learn more about how we can help you evaluate and qualify your staff and contractors, call us at 800.426.1604.
Day in and day out, we provide assistance to operators and contractors to solve OQ issues and arrange for expedited qualification of individuals in order to minimize interruptions to affected projects.
We rigorously review all records submitted by evaluators, contractors, operators, and others to assure accuracy and consistency. Incomplete or inaccurate records are refused and returned to the originator.
Our personnel enter data within VeriSource from these records. For data to be entered within VeriSource, we require a full audit trail and any necessary records to support that data. Assuring the quality of those records and the data entered into VeriSource gives our client’s confidence in the integrity and availability of our records and reporting processes.
For each “Record of Evaluation” submitted, we ensure that the evaluator of record has been authorized for the applicable covered task.
We believe that records and reporting are two very different things. Reporting is done through our web-based database VeriSource. The data within VeriSource indicates, for example, the name of an individual and the covered task or tasks he or she is qualified to perform. In our view, this electronic data is meaningless without the records necessary to substantiate that data. We manage not only the electronic database, but all records necessary to substantiate the electronic data maintained within VeriSource.
For each qualification reported through VeriSource, we maintain the full audit trail to support that qualification, including:
- Record of evaluation
- Documentation to support evaluator credentials
- All auditing history related to that qualification
We document the current employer for each qualified individual and allow for the transfer of those records when the individual changes employers.
VeriSource allows your personnel and your contractor’s access to reporting/analysis features including:
- Lookup of qualification data by contractor company
- Lookup of qualification data by individual’s name
- Lookup of qualification data by covered task
- Lookup of evaluator data
- Tracking/reporting “soon to expire” qualifications, suspended qualifications, revoked qualifications, and disqualifications
- Field verification tools
- Training data
- “Approved” vs. “Non-Approved” vendor data
- Other customized reports
We also provide toll-free telephone access to assist your personnel and contractors with real time verification of qualification status.
Evaluators – We routinely monitor evaluator performance to ensure that evaluations are conducted in accordance with your OQ program and our procedures. Evaluators are randomly selected for audit, but may also be audited on a “for cause” basis when there is evidence to suggest procedural violations.
Qualified Personnel – Random and “for cause” audits are conducted of previously qualified individuals to ensure they have not contributed to an incident/accident while performing a covered task(s) and to ensure there is no other reason to suspect the individual may no longer be qualified. All personnel audits are conducted relative to all applicable operator clients to promote economies of scale.
Records – As the last step in concluding an evaluator or qualified personnel audit, all internal records are audited for completeness and accuracy, and to assure that electronic records within VeriSource are consistent with submitted records.
We have employees dedicated to providing technical support to your personnel and contractors for help in navigating VeriSource, and to solve other technical issues as they arise.
We support you in preparing for and undergoing Federal and state OQ inspections. We like to be there at the inspection, to describe and document qualification activities, procedures, records, and to help you demonstrate compliance.
On a quarterly basis, we host a meeting for all of our operator clients to come together to discuss issues, challenges, program improvement ideas, best practices, lessons learned, and the compliance experiences of individual operators.
We can also provide assistance in investigating incidents or accidents reported during the audit process to determine need for re-qualification.
To learn more about these or other supplemental OQ services we offer, call us at 800.426.1604.