Welcome back to our overview of the PHMSA 9 Protocols/Form 14- 22 Elements. As we mentioned in our last few articles, PHMSA’s 9 Inspection Protocols historically were listed 1-9 with each having several sub-parts. In August of 2013, PHMSA split the nine protocols into individual sub-elements. These are now listed numerically on PHMSAΓ’s Form 14.
In this post, we will look at numbers 8 and 9 which address the requirements for documenting evaluation methods within your program.
8. Evaluation Methods (detail) Are evaluation methods established and documented appropriate to each covered task? (TQ.OQ.EVALMETHOD.P) (detail)
192.805(b) 192.803 192.809 (d) 192.809(e)
192.805 (b) requires that an Operator ensure through evaluation that individuals performing covered tasks are qualified. 192.809 (d) confirms that work performance history can no longer be used as the sole qualification method and 192.809(e) does not allow on-the-job performance as the sole qualification method.
CFR 192.803 defines evaluation as: A process established and documented by the operator, to determine an individual’s ability to perform a covered task by any of the following:
(a) Written examination
(b) Oral examination
(c) Work performance history review
(d) Observation during
(1) Performance on the job
(2) On the job training
(e) Other forms of assessment
A task list must designate both the evaluations required to qualify for a given task and the evaluation methods that will be used to do so while also adhering to the guidelines set out in 192.809 that on-the-job observation and work performance history cannot be the only methods used.
9. Evaluation Methods (detail) Do records indicate evaluation methods are documented for covered tasks and consistent with personnel qualification records? (TQ.OQ.EVALMETHOD.R) (detail)
192.805(b) (192.803; 192.809(d); 192.809(e)
Number 9 covers the same regulations as Number 8 but Number 9 sets requirements for the evaluation records themselves. It is the responsibility of the Operator to keep accurate records of not only the outcome of evaluations but also the methods used and to ensure that the methods stated in the OQ Plan are the same methods evident in the qualification records.
The responsibility for record-keeping will be covered in more detail when we examine Protocol 12 in a few weeks.
In each of the next 5 issues, we will continue our coverage on the protocols until we have completed PHMSA’s Form 14. For more information on the Protocols or Form 14, please visit PHMSA’s website.