On May 25, 2022, we hosted our most recent webinar in the Regulation Navigation with Warren Miller series discussing the recent changes to the New York OQ Rule and what implications this change may have on the industry. To summarize our session, our team put together a list of the Top 5 Takeaways from the discussion. Check them out!
- New covered tasks must be fully developed, with consideration to Span of Control (SOC), re-evaluation intervals, and critical questions covering Abnormal Operating Conditions (AOCs).
It is important as an operator to develop the new covered tasks that will be performed on your facility, considering Span of Control, re-evaluation intervals, and critical AOCs. Keep in mind that all AOC’s are now critical in the state of New York.
- Training requirements must be established for all covered tasks.
Make sure that you address any new and old covered tasks, acknowledge the minimum requirements for the task, and establish training as needed. We recommend performing a needs assessment on new or tenured personnel to determine what amount of training may be required.
- Evaluation methods may have to be amended to capture the operation of different equipment and for physical abilities.
As an operator, you may have to amend the evaluation methods to capture the operation of different equipment, physical abilities, and knowledge skills and ability for each employee’s covered tasks.
- Develop procedures to measure program effectiveness and gather information needed to make the measurement by 3/18/2025.
This is a brand-new term for most and is now required for operators in New York to develop, gather information, and measure the program as warranted by the findings of that review.
- Ensure adequate evaluations are performed and separated from documented training for 48 hours.
Regulators will be looking for timed recordkeeping of training to ensure that 48 hours has passed before performing evaluations. This drives operators to have a clear delineation between training and evaluation and to make sure their personnel retain that information for the long-term.
We invite you to sign up for our next webinar on Wednesday, August 10 as we continue our discussion on the New York OQ Rule and hear from operators on how they plan to navigate these new changes.
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.