Paper copies of this document are uncontrolled. Refer to www.bppipelines.com for the most current version.
The U.S. Department of Transportation (DOT), Pipeline Hazardous Material Safety Administration (PHMSA), requires pipeline operators to develop a written qualification program to evaluate the ability of employees and contractors to perform “covered tasks” and to recognize and respond to abnormal operating conditions that may be encountered while performing these activities. Design and engineering tasks are excluded because assurance of their quality is provided by the fact that appropriately educated or experienced individuals perform these tasks using guidelines and procedures for the conduct of their work. In addition, the quality of the work product is generally confirmed procedurally through review and ultimately by field inspection and testing of the design.
BP’s OQ Pipelines Operator Qualification program will be revised as regulations change, and when new information, or experiences with the plan are encountered. The BP Pipelines OQ Committee will review the plan on an annual basis. This is a performance-based qualification program. The regulations can be found in 49 CFR Part 192 Subpart N (gas) and Part 195 Subpart G (liquid).
BP Pipelines (North America), Inc. (Company)US Pipelines & Logistics includes all wholly owned, subsidiary, and joint venture business activities. The Company’s OQ program is designed to ensure that all individuals working on the Company’s regulated pipeline facilities are qualified to perform specific “covered tasks” and to reduce the probability and consequences of incidents/accidents.
The OQ Committee is responsible for the development and implementation of the OQ plan elements. The OQ Supervisor(???)Coordinator is responsible for communicating the plan elements (including revisions) to Team Leaders/ Supervisors/ Managers.
October 27, 1999 – Individuals who were performing a covered task(s) on a regular basis prior to this date will attain the level of transitional qualification for that specific task(s) by a satisfactory review of work performance history. All other Individuals must complete an initial qualification prior to performing any covered task(s) after this program has been approved by BP.
April 27, 2001 – DOT deadline for written program; BP Pipelines OQ Plan Implementation.
October 28, 2002 – All Individuals must be qualified.
October 29, 2002- Work performance history review cannot be used as the sole method of evaluation.
December 17, 2002-Pipeline Safety Improvement Act enactment date.
December 17, 2004-Pipeline Safety Improvement Act compliance date.
September 15, 2006 – Publish date of the ASME B31Q Standard
Who is affected?
All Operations and Maintenance personnel, which include company and contract field personnel and Control Center personnel, performing Covered Tasks on DOT regulated facilities are affected.
2. Premises and Definitions
Covered Task - an activity by an individual or group of individuals that (a) is performed on a pipeline facility and; (b) is an Operations or Maintenance task and; (c) is required by Part 192 or Part 195; and (d) affects the operation or integrity of the pipeline.
Performed on a Pipeline Facility
Performed on a pipeline facility - an activity that is performed by an individual or group of individuals whose performance directly impacts the pipeline facility.
Pipeline Facility is new and existing pipe, rights-of-way and any equipment, facility or building used in the transportation of hazardous liquid or gas.
Activity means physical, visual or mental effort directed at achieving a result.
Removed from the system means that a part of the pipeline system is physically removed or isolated from the pipeline system.
Pipeline System means all parts of a pipeline facility through which a hazardous liquid or gas moves in transportation (line pipe, valves, appurtenances, pumps, compressors, meters, tanks, etc).
Operations and Maintenance tasks - activities done by an individual or group of individuals (1) to perform a function on a pipeline facility; or, (2) to provide upkeep of a pipeline facility.
A “new construction task” changes to an Operations and Maintenance task when the pipeline facility is being commissioned or during the act of connecting to an active pipeline facility.
New construction means the act of building a pipeline facility, or expanding an existing pipeline facility (as in looping a pipeline segment, which may also be done to meet increased load requirements or to enhance reliability of the system) in order to provide new service to a customer(s) or in order to meet increased demand.
Fabrication of new elements installed as part of a maintenance/repair or “replace in kind” activity are Operations and Maintenance tasks.
Emergency response activities are not Operations and Maintenance tasks.
Activities on pipelines that have never been in service or fabrication of new installations associated with new functions or services are not Operations and Maintenance tasks.
Required by Part 192/195
Required by Part 192/195 - only those tasks specifically required to be addressed in Parts 192/195. State and local requirements are not applicable to this rule.
Affects the Operation or Integrity of the Pipeline
Affects the operation or integrity of the pipeline - activity that could directly or indirectly cause the release of hazardous liquid or gas to the environment or result in a hazard to persons or property.
Pipeline means all parts of a pipeline facility through which hazardous liquids or gas move in transportation (line pipe, valves, appurtenances, pumps, compressors, meters, tanks, etc.)
An affect can be either immediate (direct) or delayed (indirect)
The integrity of the pipeline refers to the pipeline’s ability to operate safely and to withstand stresses imposed during operations.
Evaluation - a process established and documented by the Company, to determine whether an individual is qualified to perform a covered task.
Qualified - an individual has been evaluated and
Can perform assigned covered tasks
Can recognize and react to Abnormal Operating Conditions that exist for the covered task for which the individual is evaluated and that result from or are encountered during performance of a covered task.
Regulatory Compliance documentation has been completed
Individual - a person, who on behalf of the Company performs one or more covered tasks on a pipeline facility operated by the Company.
Operate - start, stop, open, close and monitor.
Elements - activities that are part of a covered task. The list of elements in the OQ Plan are not intended to be all inclusive and could vary by location.
Abnormal Operating Condition - a condition identified by the Company that may indicate a malfunction of a component or deviation from normal operations that may indicate an operating condition that could exceed design limits or result in hazard (s) to persons, property, or the environment.
NOTE: A deviation from normal operation does not necessarily mean an abnormal operating condition exists as long as conditions are within the parameters identified by the Company
5. Contractor Qualification
Performing Covered Tasks
Effective 28 October 2002, the Company requires contractors to furnish qualified individuals to perform the Company’s covered tasks. These requirements are identified in the Contractor Management Manual - Tab 17 (Operator Qualification). The contractor must use a process for evaluation and records retention that is acceptable to the Company’s OQ Plan Administrator and in accordance with 49 CFR Part 192.807 or 195.507. During the planning and/or execution stages of each job, the Company’s representative in charge of the job will:
Identify any covered tasks to be performed.
Ensure that a qualified individual will perform the task or that a qualified individual will be present to direct and observe performance of the covered task by a non-qualified individual.
Interrupt work done by contractor employees if work is performed in a manner inconsistent with the Company’s OQ Plan and request additional qualification or other appropriate action.
Require from the contractor a list of employees and covered tasks they are qualified to perform, method used to qualify and expiration date of said qualification, along with notification of any employee changes made during the work. Company will maintain such records as part of the job file. BP Pipelines maintains two ISN accounts to manage job site qualification records.
Ensure that all subcontracted work is performed under the same qualifications processes.
Identify contractor employees where the English language is not understood or considered a second language and/or provide a means for translation.
The Company will maintain a list of acceptable qualification evaluations methods for contractors performing specific covered tasks on the Qualifications Chart for Contractors and will publish this document on the Company’s public website for contractor access and review. These methods will consist of industry-developed evaluation and record keeping processes as developed by organizations such as the National Center for Construction Education and Research (NCCER), American Petroleum Institute (API), OQSG or vendors with specialized industry-recognized technology such as TD Williamson and Clock Spring that have been specifically reviewed by the Company or industry representatives. In isolated cases, contractors may be qualified under the company’s own evaluation processes identified on the Qualifications Chart for Contractors.
D. Glossary of Terms
CRU CRUDE FAC FACILITY – PUMP STATION, VALVE SITE, ETC. FS FIELD SPECIALIST HMI HUMAN MACHINE INTERFACE (EXAMPLES – DATA PANEL, MINIOPS, ETC)
HVL HIGHLY VOLATILE LIQUID
HYD HYDRAULIC CMMS COMPUTER MAINTENANCE MANAGEMENT SYSTEM MAOP MAXIMUM ALLOWABLE OPERATING PRESSURE AS DEFINED IN THE OMER MANUAL
MODP MAXIMUM OPERATING DISCHARGE PRESSURE AS DEFINED IN THE OM&ER MANUAL OMER OPERATIONS MAINTENANCE & EMERGENCY RESPONSE OJT ON THE JOB TRAINING CRTS COMPUTER RECORD TRACKING SYSTEM
PID PROCESS AND INSTRUMENT DIAGRAM OR IN REFERENCE TO A CONTROL LOOP – PROPORTIONAL, INTREGAL, AND DERIVATIVE