Would you let your teenager drive your car when they’d only taken an online driving class and answered a set of test questions? Not likely! You’d want them to demonstrate they can safely drive a vehicle with an actual driving test. Similarly, I believe that most pipeline operators would agree: properly qualifying personnel to perform specific kinds of work on their pipelines requires much more than having them take a written or online test. An OQ program is not just about checking off a set of compliance boxes. A fully-qualified contractor workforce is key to safe and effective operations, and thus is key to the success of the business. It’s why Veriforce and our clients invest a significant amount of time and effort toward establishing effective operator qualification programs that incorporate a rigorous upfront process, as well as ongoing checks and balances to validate the integrity of qualifications.
A cautionary tale
At our winter client meeting in February, a topic of particular interest during the OQ breakout was the recent New York State Public Service Commission investigations of alleged cheating on operator qualification exams. The initial media report in December told of allegations and related investigations involving a single contractor whose workers were suspected of having access to, and likely using, test questions and answers for qualification exams – exams that deemed them qualified to work on a pipeline. A follow-on report in January revealed that a second contractor was also being investigated.
Similar allegations have surfaced in at least one other state. It appears in these cases that administration of a written qualification exam may have been the primary process for qualifying workers to perform pipeline tasks.
The discussion among participants in the OQ breakout at the Veriforce client meeting focused on the potential consequences if crews on one of their jobsites were caught cheating – the disruption to the job, the need to requalify, or find new qualified individuals, the expense of going back and validating, or redoing, work that had already been done – and their desire to avoid that scenario. Even the suggestion of a defective qualification process for pipeline workers, whether due to suspected cheating, negligence, or other issues, could be sufficient to shake public confidence in the safety of a pipeline and to cause remedial steps to be taken on work already completed.
We’ve got your back
At Veriforce, we’re very mindful of the trust that our clients place in us to help them ensure that their contractors are fully qualified. We take our responsibility very seriously. For our clients, requiring that an individual complete a training course for a covered task and successfully pass an online test is often an important part of the qualification process. However, that is not sufficient. The real determination of whether an individual is qualified comes with the completion of an evaluation of their knowledge, skills, and abilities. Until an individual can demonstrate their ability to safely perform a specific pipeline task under the scrutiny of an evaluator who has been vetted and authorized by Veriforce, they are not awarded a qualification for that task.
That’s where Veriforce’s authorization program for contractors’ evaluators plays an important role. Rather than give broad approval to conduct evaluations for any task, we limit an evaluator’s authorization to specific task categories. Candidates must certify in their application their status as a SME (subject matter expert) for requested task categories, and provide three technical references (as well as two character references). Our required Evaluator Authorization Training provides evaluators with in-depth instruction on properly conducting OQ evaluations. Not only do we train evaluators, we routinely audit Veriforce-authorized evaluators and qualified individuals to ensure that evaluations are done properly and qualifications are only awarded to those who show that they can competently and safely perform covered tasks. Most of our audits are random, but we also watch for red flags and perform audits where we see higher risk. For example, an evaluator putting in place an unrealistic number of qualifications in a single day would likely trigger an audit. As a result, Veriforce clients can have the confidence that processes, along with appropriate checks and balances are in place to ensure that the workers on their pipelines are truly qualified to perform the required work, and that as operators, they can effectively defend their OQ programs to PHMSA and state regulators.
About the Author
Tom Meek is the Compliance Director for Veriforce and has 20 years of experience in the natural gas business, with pipeline companies throughout the US. He has expertise in OQ task and training development, compliance, emergency response, O&M development, and damage prevention and serves on several industry standards committees.