Municipal Natural Gas Pipeline: The Vital Role of OQ

The natural gas pipeline is the unsung hero of our neighborhoods, providing energy to warm our homes, cook our food, provide hot water, and fire up our barbecues. Communities across the globe depend on natural gas. In fact, in North America, it is the second most used energy source in homes, behind electricity. But while we’re warming our toes by the gas fireplace in the middle of winter, we rarely think about how energy reaches our homes safely.

The operation and safety of a natural gas pipeline comes down to a single critical element: Operator Qualification (OQ). This article outlines the importance of why municipalities need to ensure they have a defensible OQ program to keep workers and communities safe.

Operator Qualification Explained

Here is a brief overview of what is involved in developing a compliant OQ program.

Elements of an OQ Program

Federal (PHMSA) and state regulations mandate pipeline operators to have a written OQ program. This ensures workers performing safety-sensitive tasks or “covered tasks” on pipelines are qualified to do the job. Workers must be trained, tested, and certified to perform certain operations and maintenance tasks. The key aspects of OQ are:

• Identifying all covered tasks that may affect the safe operation of the pipeline.
• Maintaining records that document the qualifications of workers.
• Regularly reevaluating workers to ensure qualifications are current and up to date.
• Providing training to ensure workers are qualified to perform their assigned covered tasks.
• Developing procedures (in writing) and evaluation criteria to test a worker’s skills, knowledge, and abilities to perform covered tasks.
• Evaluating workers using written exams, questioning, observations, etc. to confirm they can recognize abnormal operating conditions.

Covered Tasks

Covered tasks vary, depending on the type of pipeline an individual is working on. For the purpose of this article, examples of covered tasks for a municipal natural gas pipeline may include:

• Pressure testing
• Investigating incidents
• Incident response procedures
• Purging
• Repairing leaks
• Corrosion control

Pipeline operators must have a comprehensive covered task list. Furthermore, each covered task must have its own written procedures, qualification process, and evaluation criteria. This ensures workers are properly trained and evaluated based on the covered tasks they are responsible for.

It’s important to note that Pipeline and Hazardous Materials Safety Administration (PHMSA) regulations state that covered tasks must meet the following four-part test:

1. Performed on a pipeline facility.
2. An operations or maintenance task.
3. Performed as a requirement of the pipeline safety regulations.
4. Could affect the operation or integrity of the pipeline.

A holistic approach to a municipality’s OQ program will result in a competent and safe workforce to ensure public safety and prevent incidents from occurring.

Why Cities Need an OQ Program

On the afternoon of September 13, 2018, a major natural gas pipeline accident happened in Merrimack Valley, Massachusetts. Low-pressure distribution systems are most common in municipalities. It’s the system that delivers natural gas directly to our homes.

The accident was caused by high-pressure natural gas getting released into a low-pressure system. The result was catastrophic. Natural gas explosions leveled 131 structures, including homes. One person died and 22 others, including first responders, sustained injuries.

While many factors caused this accident, one of them was the improper qualification of workers, including contractors (National Transportation Safety Board Report).

This is why a robust OQ program matters to municipalities. It all boils down to safety.

Benefits of an OQ Program for a Municipal Natural Gas Pipeline

A comprehensive, well-defined, and implemented OQ program offers several benefits for both the operator and the community:

• Enhanced Public Safety: Many pipeline incidents are the result of human error. As such, an OQ program minimizes risk by ensuring workers are trained and qualified to perform their assigned covered tasks. This reduces incidents that can threaten the surrounding community.
• Sustainability: OQ programs align with a community’s environmental goals. Sustainability initiatives for cities usually include the municipal natural gas pipeline. Today’s OQ programs are designed to include training on tasks related to emissions reduction and efficiency optimization.
• Reliable Gas Service: An incident or accident could result in a natural gas pipeline disruption. In some cases, as a safety measure, the natural gas is turned off until the incident is resolved or the pipeline is repaired. That’s not ideal if you live in a cold climate. A qualified workforce helps to mitigate risk and prevent incidents from occurring.
• Compliance: PHMSA requires all pipeline operators to maintain a written OQ program, which demonstrates an operator’s commitment to safety. Failure to comply with PHMSA regulations may result in Notices of Probable Violation, Safety Orders, Corrective Action Orders, and warning letters.
• Building Trust: As government entities serving local communities, municipalities have a responsibility to demonstrate their commitment to safety and environmental protection. A properly implemented OQ program inspires public confidence that a solid method is being used for pipeline safety and environmental protection. This transparency builds trust and strengthens the city’s relationship with the community it serves.

Extending OQ to Contractors

Municipalities may insist contractors have their own OQ program that complies with the municipal regulations. The municipality has to agree that the contractor’s program meets PHMSA regulations. There are a few stipulations for extending OQ to contractors:

• Contractors can qualify their own workers directly into the municipality’s OQ program by following the same evaluations, procedures, and recordkeeping requirements.
• Municipalities are allowed to accept qualification records from contractors, who are evaluated by an approved third-party OQ company if they meet the requirements of the municipality.
• For any worker assigned covered tasks, municipalities need to verify that the worker is either qualified or directly supervised by a qualified person holding a position or title within the municipality.
• Records must be kept that show in detail the basis for the determination that each contractor employee is qualified to perform covered tasks, by virtue of a program approved by municipalities, the contractor’s program, or through a third party.
• Municipalities can request audits of contractors regularly to ensure they are still in compliance with the requirements and qualifications.

Municipalities are facing mounting pressure to minimize the risks of using contractors on their natural gas pipeline system so extending the OQ program to contractors is a must.

Municipalities Require the Right OQ Partner

One of the most widely recognized OQ partners for city gas operators is Veriforce. Our operator qualification compliance solution includes software, documentation and reporting, audit support, evaluator authorization, and training content — everything you need to ensure a defensible operator qualification program. We customize each program to suit the municipality and adhere to the needs of both clients and regulations.

Veriforce supports municipalities in developing the best OQ program possible for their workers, the environment, and the people and communities in their jurisdiction. Allow us to help you create a vision for a future where communities prosper and energy is safely and competently delivered by pipelines, managed by qualified workers.

Contact us today to learn more.