by Claude McKee, EWN Compliance Management Specialist
Do you check your OQ training at least annually to review employee pass-fail rates and assess which evaluation questions are missed? If not, you are treating evaluations as if they are nothing more than pass-fail documents. Without submitting failed evaluations, you cannot rely on your data. Without correcting problems associated with the relationship between your evaluations and your OQ training, you end up training people to pass the evaluation and then have to actually teach them how to do the job later. This can cost you time, money, and can even lead to a dangerous situation between the time employees pass an ineffective evaluation and the time when they are eventually trained properly.
You Should be Evaluating Your Evaluations
Your evaluations are a way to ensure your training is relevant and effective. Performance of the task is, without a doubt, the best evaluation method. If something is missed here, you need to know it. Even the submission of failed performance evaluation can be a key indicator of knowledge transfer problems. PHMSA has implied that performance of the task should be a part of the evaluation process. If your evaluations do not match your process, then it’s time to change them.
EWN encourages clients to take ownership of their OQ program and make them their own. EWN works continuously to update and create content that aligns with the most widely-accepted Industry Standards and Practices. We currently have over 400 OQ computer-based trainings, so chances are we have something that is applicable to your unique tasks. Updating your current methods can be an effective way to improve your qualification process.
Trying to Make an ‘Off-the-Shelf’ Program Work
Governmental entities and associations across the nation are stepping up and speaking out with a clear message: Off-the-shelf, cookie-cutter programs are not effective. When an Operator’s AOCs (abnormal operating conditions) are not addressed in their training and evaluations, it can lead to problems, and these governmental entities and associations are taking notice. In a recent report, one state agency proclaimed, “Allowing Operators to be ‘qualified’ without a hands-on experience and a proper evaluation of AOCs fails to ensure the safety of the gas system.”
If your OQ Plan doesn’t address your AOCs – or if you need to create supplemental training that addresses your specific needs, you need to create custom content. The EWN Content Authoring Tool can help you create critical questions that address your AOCs. If these questions are missed, the system can initiate an automatic fail. Adding these critical, operator-specific questions can be used to ensure that the question has been read and understood, leading to increased peace of mind that the employee has been trained appropriately.
Task List and Performed Tasks Inconsistencies
Is your task list consistent with what is being performed on your pipeline and at your facilities? Too often we see tasks not being performed but still included in the Operators task list and OQ Plan. If its not in your O&M, not performed on your pipeline, or if it does not meet the four-part test, it’s not a covered task and should not be included in your OQ task list.
EWN suggests that Operators review their task list annually to ensure any adjustments be made to keep their task list current. EWN gives you the ability to create non-covered tasks the same as a covered tasks, ensuring consistency in your training program. These tasks remain separate from your OQ Program. Industry standardized task lists are great tools and make things simple, but take time to customize based on special requirements. If you are struggling with your task list, let EWN help you to create or update a task list that is specific to your company’s OQ requirements.
About the Author
Claude McKee serves as a Compliance Management Specialist at EWN. His vast experience in the industry, including welding, fabrication, oil and gas production, DOT, and hands-on experience as a pipeline worker.
For more information, contact the EWN Compliance team at firstname.lastname@example.org