Managing your task list doesn’t have to be tedious or daunting. At EWN, we are committed to providing clients and the industry with the most intuitive information you can use to manage task lists more effectively.
We recently met with Operators across the industry and found several common challenges they’re facing regarding task list management. In this article, we will cover some of these issues plus our solutions and recommendations on how to help manage tasks lists.
You have been promoted to manage the company’s OQ (Operator Qualifications) Program. The company’s task list was created by one, two, or even three of your predecessors. The task list has not been touched in several years, and you choose not to make any additional changes. After all, whomever created the task list must have known what they were doing, and since it has worked all this time, why change it?
What we found was that new personnel charged with managing the OQ Program were never properly trained on how to manage the existing program or were not informed of changes and decision made to develop the existing program. In other cases, the answer was simply that it had always been done that way.
It is absolutely okay and necessary to make changes to your OQ Program and update your company’s task list. Are you aware that 49 CFR 192.605(a) and 195.402(a) requires that each Operator prepares a manual of written procedures for conducting operations and maintenance activities, and that this manual must be reviewed and updated by the Operator at intervals not exceeding 15 months, but at least once each calendar year? By extension, if you modify your O&M (Operations and Maintenance) manuals, you’ll also need to review and update your OQ Plan, task list, and associated methods of qualifications for the same period of time to reflect any changes in your programs or operations. By doing this, you will ensure that your company is in compliance with federal, state, and company requirements.
If you can relate to this too, don’t worry as you are not alone. While managing a task list can seem intimidating because there are so many moving parts, it can be done. Start with understanding your responsibility for your company’s OQ Program. It is the responsibility of the Operator to identify covered tasks, the requalification intervals, span-of-control ratios, and evaluation methods. This is what is required by 49 CFR 192 Subpart N and 49 CFR 195 Subpart G. But what isn’t always clear are all the other nuances that will impact your task list. Take for example this scenario:
The Operator uses a contractor to perform specific tasks such as hot-tapping or welding. Because these activities are performed by a contractor, the Operator does not include these tasks in their task list. After a regulatory audit, the Operator receives a citation for not including these specific tasks in their task list. But why?
By law, the OQ Rule covers all the Operator’s workforce including employees, contractors, and sub-contractors. So, contractors do not differ from employees when it comes to the regulations. Therefore, you need to include these tasks in your task list even if they are performed by a contractor. Also, be sure to clearly state in your O&M plan, OQ Plan, and SOPs that these tasks are being performed by a contractor. Consistency is crucial.
Here’s another scenario:
The Operator identified covered tasks with associated Abnormal Operating Conditions (AOC) for their gas pipeline facility. The Operator assumed that these tasks and AOCs could also be used to qualify personnel performing covered tasks on their liquid pipeline facility.
The issue is that you cannot assume that your identified tasks are a one-for-all when it comes to compliance for gas and liquid facilities. The operation and maintenance for a gas pipeline can differ from that of a liquid pipeline. Likewise, the AOCs (Abnormal Operating Conditions) encountered on a gas pipeline would not be the same AOCs for a liquid pipeline.
We recommend that you identify covered tasks for each facility and uniquely label them gas or liquid. Confirm that each task includes task-specific abnormal operating conditions and that they meet the requirements for each facility type. Keeping each task separate from each other will also help streamline your process. While you can potentially combine a task to be both gas- and liquid-specific, think about a situation where you may have an individual who can only perform gas-related tasks. If the task includes both liquid and gas, this individual will now have to take the liquid criteria to qualify for the task.
Making significant changes to your task list also requires Operators to notify their state agency of the changes. According to the Pipeline and Hazardous Materials Safety Administration, a “significant change includes but is not limited to: increasing evaluation intervals, increasing span of control ratios, eliminating covered tasks, mergers and/or acquisition changes, evaluation method changes such as written vs. observation, and wholesale changes made to OQ plan.”
Operators are sometimes hesitant to make changes to their task list because they are worried that, upon notifying the state/regulatory agency, the agency will come audit them. While this is a possibility, it is best to ensure that your overall OQ Program is effective and in compliance with regulatory requirements.
There are many variables and examples that we can explore when it comes to managing your task lists. We would appreciate the opportunity to talk to you more about this topic, so please do not hesitate to give us a call or send us an email. Further, we will also be holding a workshop that covers this very topic later this month. Join us and continue this conversation!
Register Here for the Compliance Workshops:
Minneapolis, MN – October 16th and 17th 2018