Staying Ahead of Emerging Trends in Procedure Verification for Contractors

Procedure verification of Operator Qualification (OQ) tasks has always been a requirement for conducting operations and maintenance activities, including emergency response. In fact, the U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA) makes it clear in its OQ Frequently Asked Questions that operators are required to ensure all individuals, including contractors, perform work according to the operator’s procedures.

Today, however, trends toward confirmation of procedure verification on an individual basis and required training on those procedures are emerging — led by New York’s March 2022 amendments to regulations governing the transmission and distribution of gas.

At the national level, there are no formal best practices around procedure verification. So, how can you ensure workers on your site are performing their tasks according to your operations and maintenance procedures on an individual level?

With employees, it’s easier to verify they understand your procedures and follow them. However, when engaging a third-party contractor to do the work, there are fewer ways to confirm compliance. Additionally, it is expected that New York’s compliance rules will spread procedure verification requirements to other states quickly.

Ensuring verification of policies and procedures

Connecting policies and procedures to an individual is possible not just through communication of those procedures, but by connecting them directly to the task they are performing.

A pipeline operator uses the following four-part test to identify an OQ task:

1. Is it part of the regulation?
2. Is it performed on the pipeline?
3. Does it impact the safety or integrity of the pipeline?
4. Is it part of my operations and maintenance manual (i.e., is it part of my policies and procedures?) 

Once the operator has gone through the four-part test, the policies and procedures are technically connected to the task.

But how can you verify the contractor will actually implement the policies and procedures on the job? That’s where creating a formal evaluation or test to verify access to procedures and performance of the tasks being performed to meet expectations comes into play.

3 ways to ensure your OQ program is foolproof

How can operators ensure contractors are verified on procedures and understand them? Start with these tips to fill the gaps and verify them: 

1. Identify procedures and assign them proactively. Let’s say the task is “operate valves.” The pipeline operator sends the sections of the manual pertinent to the operation of the valves to the contractor, then creates a test or acknowledgement that the procedures were received and understood. After that, verification is attached to that individual’s ready-to-work status. If they go to work for another hiring client, they’ll need to review and verify those procedures before they’re allowed to work there. 
2. Training does not equal qualification. Training is important, but it is a means to an end. A person can be trained on a task but never qualify to perform that task because they couldn’t pass an evaluation to become officially qualified in the task. Conversely, qualification can happen without training. Someone may have previous related experience to perform the task by passing the evaluation without a minute of training on that specific task under their belt. Consider the differences between the two and build your training and qualification programs accordingly. 
3. Procedures vary and change. If everyone had the same facility and qualified staff in the same geographic area with the same climate, then policies and procedures would be the same across the board. However, the procedures for pipeline evacuation in rural New Mexico, for instance, are quite different from those to perform the same task in New York City. Additionally, different operators place different emphasis on best practices for tasks and procedures. Procedure verification is confirmed by a separate training or acknowledgement event. As procedures change, a worker may have to take subsequent training and/or requalification, or merely receive a notification of change depending on the significance and impact of the change, in order to remain in ready-to-work status. 

Today, requirements say operators only need a worker who is operator-qualified to put them to work in a basic setup. But progressive operators with more mature compliance programs anticipate what’s on the horizon and make adjustments to confirm understanding of the operator’s specific procedures at the individual worker level.

To create the safest and highest quality control situation while also being prepared for future regulatory changes, operators should add training and procedure verification to their requirements for a ready-to-work employee or contractor.