Pipeline Operator Qualification has two sides. Safety is one and it is paramount. The other side is dollars-and sense. EMS supports the adoption of a single Operator Qualification standard, accepted and implemented industry-wide, that would reinforce safety in the field and generate substantial savings in time and labor.

A few months ago, a pipeline explosion rocked the northwest part of a major US city. A third-party bulldozer operator hit the pipeline. The dozer operator quickly notified the pipeline operator, which began to immediately to shut down nearby valves and alert civil authorities. But something sparked – the escaping gas exploded. Fortunately, only a single very light injury was reported and authorities brought the fire under control promptly.

This was an accident. The pipeline operator had procedures in place to respond promptly to the situation. But it has raised questions again…and not just about the comprehensiveness of the training demanded of anyone working in a pipeline right-of-way or a high-risk area.

There’s the question of whether or not there should be a single standard of Operator Qualification (OQ) training for everyone working on pipelines in the US.

As of the end of October, 2002, every individual who performs tasks related to pipeline operation, maintenance and repair must be qualified in accordance with 49CFR Part 192, Subpart N (Gas) and 49CFR Part 195, Subpart G (Liquid). This is the guidance for OQ standards laid down by the Federal government.

In every company, workers and supervisors are OQ-ed to do a specific task. But many companies use different OQ systems. When maintenance specialists leave one pipeline company to work for another, they are often challenged to learn new company-specific qualification procedures, which are designed to satisfy three or four different regulatory or corporate agencies.

When you train someone in one system, then re-train him or her for work with another company’s line, it can not only lead to safety issues, because of mixed training and confusion of procedures. It’s expensive for the operator in time and money.

There’s no one OQ plan that’s universally mandated or accepted. For example: Operator A sells an asset to Operator B, who in turn sells the asset to Operator C. The operating personnel who stay with the asset end up having to change their procedures because each of the corporate plans is different.

When you use third-party inspection, maintenance and repair firms, each firm must ensure that their employees are OQ-ed in each customer’s approved procedures. This may involve two, three or even more “systems” under which the third-party vendor has to work.

Remember: the mission is to maintain pipelines and improve maintenance procedures in accordance with the US Department of Transportation as well as the oversight commissions in the various states where pipelines operate. This covers not only the craft work and the supervisory procedures; it applies to environmental issues, air quality, annual filings – all to support government-mandated integrity management programs (IMP).
Just as there’s no one proper IMP, there’s no single, approved OQ methodology. We suggest that so much cross-training (with inevitable variances from operator to operator) is at cross-purposes with the industry’s best interests. There’s a lack of consistency.

Is There A Drive for A Single Standard? Yes and…
Yes. Industry professionals are pushing for consistency. Let’s be clear and fair. There are both association-based and private-sector programs that a large number of operators use or support.

The National Center for Construction Education and Research has established a Pipeliner training and Assessment Program: Operator Qualification for Liquid & Gas Pipelines, cooperating with the American Petroleum Institute. Its program consists of pipeline curriculum and pipeline skills assessments to qualify pipeline personnel under the US Department of Transportation’s regulations for Pipeline Operator Qualification.

Even more promising is the effort by the American Society of Mechanical Engineers related to its long-time work on B31Q, a pipeline welding standard. The B31Q Project Team has included representatives from federal and state regulatory agencies, contractors, industry associations, labor and three industry sectors – hazardous liquid, gas transmission and local distribution companies. In all, more than 100 people have worked hard to develop a technically based standard while recognizing the diverse needs of the industry and regulators at the same time.
The Society’s consensus process was completed with approval of B31Q as an American National Standard on July 10, 2006, and it published B31Q on September 15, 2006. Just as it took many years for the B31Q to be developed, though, it is going to be a long time before operators as well as regulators adopt it as the “industry standard.”

A number of private-sector firms provide trained and certified evaluators to administer pipeline OQ evaluations. EMS itself uses ISNetworld for its own OQ program company-wide.

Ours is an OQ system that combines oral and observational approaches. It is comprehensive. But we also train and certify through up to five different qualification processes, which include the National Center for Construction Education and Research and the Mid-American Energy Association. EMS rigorously follows this training process, combining book knowledge and field training.

EMS also cross-trains its maintenance and repair personnel and supervisors to meet the standards of its customers’ accepted programs. Crossover training is a contractor’s responsibility and we take it seriously.

…And No, Standardization Is Lagging.
Each operator may use different OQ procedures, because “it’s our way.” Procedures vary because of company structures, geographic or regional issues, or confusing and sometimes conflicting state regulations. First, despite widespread safety consciousness, there’s no enforced and enforceable technical standard to rely on for OQ. There’s a continual demand for re-training and cross-training, which can result in confusion. Despite the wide range of available training methods and tests, passing them doesn’t mean you can do the work; and when you go out to the field, you may not actually be able to do the work. It’s a classic case of book learning versus hands-on field experience. In the past, there was a “gang system,” similar to training programs in other industries. You worked on a gang and you learned, hands-on, as you went along.

Over the past 20 years, as operators have outsourced the maintenance tasks, third-party contractors are the “gang.” We all train and work to reduce confusion but the array of differing procedures can be a barrier to prompt and proper actions in the field.

Second, operators write their own OQ procedures and operator or third-party personnel have to retrain on them. Whether it’s the number of hours covered under an operator’s overhead or the cost of a third-party maintenance firm, that time is money.

No figures are available for all the expenditures involved. Under a single standard, we suggest that time spent in crosstraining can be reduced, at a minimum. That’s bound to affect not only operating expenditures but show up in business units’ bottom lines as well.

The “Solution” Is Singular but Not Simple.
We need a single OQ plan, one that everyone signs off on. We know it’s not simple, as other regulatory efforts have demonstrated. Nevertheless, the B31Q standard is the right model.

Why shouldn’t the Pipeline and Hazardous Materials Safety Administration’s Office of Pipeline Safety deliver the standardized OQ methodology? It’s the agency that enforces safety rules in the first place. Then, convince the major operators to agree and the rest of the industry will follow.

Pipeline OQ ought to adhere to a standardized, recognized and fully endorsed methodology…one acceptable standard. If this is done, then the industry can accept anyone’s OQ procedure because it will be the same nationwide. At the same time, adopting and enforcing a standard OQ procedure would curtail or eliminate the cost of retraining. It’s a dollars and- sense issue, after all.