On August 10, 2022, we hosted our most recent webinar in the Regulation Navigation with Warren Miller series gaining an inside perspective to the NY OQ Rule with Northeast Gas Association and National Fuel Gas. Chris Taylor facilitated the discussion with ITS Regulatory Compliance Specialist Warren Miller, Northeast Gas Association Vice President of Training & Qualification Services Paul Armstrong, and National Fuel Superintendent of the Mechanical and Materials Management Divisions Robert (Bob) Plewa. To summarize our session, our team put together a list of the Top 5 Takeaways. Check them out!
- The revised definition of a covered task was discussed. If that operation affects the safety and integrity of the system, it is considered a covered task and moving from a 4-part test to a 2-part test. This new definition is prompting operators to review their current covered task lists and is expected to expand the overall scope of operator qualification and likely resulting in the addition of more covered tasks.
- One major theme discovered from the changes to the NY OQ Rule is the operational ownership of OQ programs. The intent from day one has been for operators to own the OQ program and tie it back to their operations. It is vital that an operator’s commonly used tools and procedures are considered when developing covered tasks. This ensures that all who are evaluated are done so with the same standards in place.
- Ensuring competency of personnel through various methods, such as a 100% pass rate on Abnormal Operating Conditions (AOC) questions, the expanded use of performance evaluations, and documentation of training.
- Public comment is imperative! Having a seat at the table and being engaged in the rule making process is highly encouraged. This provides another take on or side to the story that regulatory agencies might not have considered. The goal is not to criticize the rule but to describe how that can affect the operator’s plan/program from a different perspective.
- The NGA program is a program developed by operators for operators. The new changes enhance the operators’ ability to make the program their own, shifting from an OQ plan to an OQ framework. This allows for the discovery of new evaluation methods that enable operators to create their own tasks/task lists on a fit-for-purpose bases in conjunction with NGA-developed written or performance evaluations.
We invite you to sign up for our next webinar on Wednesday, November 9. Registration is available now to reserve your spot.
If you have questions or concerns about the NY OQ Rule or are interested in learning more about our range of regulatory consulting services, please contact ITS Regulatory Compliance Specialist Warren Miller to learn more about how we can help you meet your compliance needs.