Program Effectiveness – The Responsibility of Everyone

What are you doing to make the world a safer place to work? Does your program continually reduce incidents or accidents caused by human error? How effective is your current OQ Program? These are some of the questions you should be asking yourself regarding Program Effectiveness.

What is Program Effectiveness?

The American Society of Mechanical Engineers (ASME) offers an explanation on the Program Effectiveness Process. B31Q Standard, Part 11.1 states that “the qualification program shall include a process to appraise its effectiveness.” That “process” includes 3 parts – (1) Program Implementation, (2) Program Measures, and (3) Program Updates.

  1. Program Implementation: is used to “develop a process to evaluate if the program is being implemented and executed as ”
  2. Program Measures: is done to “appraise the effectiveness of the program.”
  3. Program Updates: is “incorporating changes into the program to address any deficiencies found as a result of the program implementation appraisals or program measures review.”

It is recommended that you perform a program effectiveness review once every year at intervals not exceeding fifteen months. Projects, companies, and work environments change; with that, so do our OQ and other safety programs. That is why they must be reviewed annually.

Isn’t Program Effectiveness just something that Operators have to deal with?

The answer to that is no. When it comes to Program Effectiveness, it takes all stakeholders involved to buy in and ensure that the programs they have are effective and continuously improving. That way, when Operators and Contractors work together on projects, they know they are cultivating a safer work environment in which their companies’ programs are as effective as they can be.

At EWN, we often say that our goal is to continuously “Be Better.” As a pipeline facility Operator or Contractor, constantly and consistently reviewing your OQ program requirements and results for effectiveness is a solid and measurable way to be better, and in turn, make the industry better.

Operators – Raise the Bar: Operators must commit to ‘raising the bar’ and developing programs that go beyond the minimum regulatory requirements. We must all become better at what we do.  Each program must address the specific needs of the Operator, the pipeline facilities, and the environment in which they are operated.

Contractors – Offer Solutions: Contractors need to be a part of the solution, not the problem. To overcome the challenges that we face, all parties must do more and share the burden for increased expectations, accountability and transparency. For example, the Distribution Contractors Association (DCA) is spear-heading an initiative that promotes higher standards for the Contractor qualifications on core competencies. The initiative includes a whole section on Program Effectiveness Reviews that covers the process and expected outcomes for what a Contractor’s Program Effectiveness reviews should look like. This program requires the active involvement and support of Operators, Contractors, Service Providers, and Regulators to be successful; but Contractors have already voiced intent to offer solutions.

Regulators – Collaborate: Regulators themselves must be willing to engage in collaborative processes that promote voluntary program improvements. Operators that want to use a more effective solution that goes beyond the minimum requirements of the Written OQ Plan may be disincentivized if they can be cited for violating the plan.

Program Effectiveness is something in the industry that is encouraged, but not yet regulated. A direct quote from PHMSA’s Notice of Proposed Rulemaking (NPRM) Docket No. PHMSA-2013-0163, Document Number: 2015-16264 says that “PHMSA is also proposing to expand the existing Operator Qualification (OQ) scope to cover new construction and certain other currently uncovered tasks, require operators use trained and qualified individuals when performing new construction work, and add program effectiveness requirements for operators to gauge the effectiveness of the OQ programs.” If you want to learn more about these proposals, click on the following links:

(192.807) Program Effectiveness https://www.federalregister.gov/d/2015-16264/p-amd-23

(195.507) Program Effectiveness https://www.federalregister.gov/d/2015-16264/p-amd-46

 

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