Michael Comstock, the co-founder and Principal of C&M Regulatory Pipeline Consultants, joins Russel Treat to discuss operator qualification in this edition of the Pipeliners Podcast.

In this episode, you will learn about the components of operator qualification, the OQ Rule, and how operator qualification applies to contractors. You will also learn about how operator qualification was started after multiple incidents occurred in the 1990s (Bellingham incident and others).

Operator Qualification: Show Notes, Links, and Insider Terms

• Michael (Mike) Comstock is the co-founder and Principal of C&M Regulatory Pipeline Consultants. Connect with Mike on LinkedIn.
• C&M Regulatory Pipeline Consultants is a collaboration that is focused on making the natural gas industry as safe and compliant as possible, while bringing clients a unique perspective from both sides of the regulatory environment.
• The Operator Qualification Rule (OQ Rule) refers to the 49 CFR Parts 192 and 195 requirements for pipeline operators to develop a qualification program to evaluate an individual’s ability to react to abnormal operating conditions (AOCs) that may occur while performing tasks.
  • AOC (Abnormal Operating Condition) is defined by the 49 CFR Subpart 195.503 as a condition identified by a pipeline operator that may indicate a malfunction of a component or deviation from normal operations that may indicate a condition exceeding design limits or result in a hazard(s) to persons, property, or the environment.
    • Part 192, Subpart N is the minimum requirement for operator qualification of individuals performing covered tasks on a pipeline facility.
• American Public Gas Association (APGA) is the only association for municipal gas utilities in the United States.
• The Bellingham Pipeline Incident occurred in June 1999 when a pipeline ruptured near a creek in Bellingham, Wash., causing deaths and injuries. According to the NTSB report, the cause of the rupture and subsequent fire was a lack of employee training, a faulty SCADA system, and damaged pipeline equipment.
• PHMSA (Pipeline and Hazardous Materials Safety Administration) ensures the safe transportation of energy and hazardous materials.
• North Atlantic Petroleum Systems Assessment (NAPSA) fosters research collaboration between Irish and Atlantic Canadian researchers that will lead to the establishment of funded scientific projects to enhance our understanding of the petroleum geology of the North Atlantic basins.
• Northeast Gas Association (NGA) is a regional trade association that focuses on education and training, technology research and development, operations, planning, and increasing public awareness of natural gas in the Northeast U.S.

Operator Qualification: Full Episode Transcript

Russel Treat:  Welcome to the Pipeliners Podcast, episode 118, sponsored by iPIPE, an industry-led consortium advancing leak detection and leak prevention technologies to eliminate spills as pipeliners move towards zero incidents. To learn more about iPIPE or to become an iPIPE partner, please visit ipipepartnership.com.

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Announcer:  The Pipeliners Podcast where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. And now, your host, Russel Treat.

Russel:  Thanks for listening to the Pipeliners Podcast. We appreciate you taking the time, and to show that appreciation, we’re giving away a customized YETI tumbler to one listener each episode. This week, our winner is Scott Breaux with Gullet Services. Scott, if I didn’t get the company name correct, I apologize, but I figured because it’s a Cajun last name, it’s a Cajun company name. Just guessing. To learn how you can win this signature prize pack, stick around to the end of the episode.

This week, we have a first-time guest with us, Mike Comstock, who’s going to be coming on to talk to us about operator qualification, a subject I’ve been wanting to learn more about.

Mike, welcome to the Pipeliners Podcast.

Mike Comstock:  Thank you for having me. I appreciate it.

Russel:  It’s really a pleasure to have you. One of the things I’ve been trying to do is get more people on to talk about subjects I don’t know much about, and happily operator qualification kind of falls in that domain. I’m glad to have you on board.

Mike:  I appreciate the opportunity to talk about it. I’m looking forward to it.

Russel:  Maybe as a way to start, you could tell us a little bit about your background and how you got into pipelining.

Mike:  Sure. I started in pipelining in 1984 because I got laid off at a copper mine in Arizona, so I was looking for a new career and I came upon an opportunity at the city of Mesa in Arizona. When I went to work there, they gave me a shovel and said, “Dig a ditch,” and I was pretty good at that.

I continued to work my way through over a 30-year career in the city of Mesa and really took the opportunity to learn about what the pipeline industry is about and how it services the needs of the American consumer.

Russel:  Awesome. You can literally say, “I started out as a ditch digger.”

Mike:  Yes, sir. In fact, my first boss gave me a shovel and said, “Don’t look up for six months,” and so, I thought that was a pretty good training program at the time.

Russel:  Yeah, I would say that probably still is a pretty good training program. That’s literally learning the business from the ground up.

Mike:  Yes, sir. That was a good way to do it.

Russel:  How’d you get into operator qualification?

Mike:  Along about the mid-’90s, as you may recall, there were a series of incidents that occurred around the country where it appeared that either a lack of training or a lack of ability to follow procedures was one of the root causes of those accidents.

There came a discussion nationally about what does it mean to be qualified or trained in the natural gas industry. There was on the job training at that time, but really no formal process put in place.

I happened to be affiliated with the American Public Gas Association, and they gave me an opportunity through our membership, City of Mesa’s membership with them to participate as a representative of the American Public Gas Association on the committee that was put together by the federal government and the state governments to explore what it meant to have a qualification program for natural gas operators around the country.

Russel:  I’m familiar with the incidents that occurred in the mid-late ’90s, and in particular, with Bellingham, and I think most people in the pipeline business are. What I’m not familiar with is how did those incidents spawn OQ.

I mean, you kind of alluded to that as you were talking about how you got into it. What was the connection between the events, and how did operator qualification get invented or defined?

Mike:  That’s a pretty good question. Just remember that Bellingham occurred later on in the sequence of events that transpired. In the early, mid-’90s, there were a couple of incidents that centered around the lack of following procedures and processes in an operator’s Operation and Maintenance Manual.

The discussion became, “Are people adequately trained to follow those procedures, or is on the job training sufficient enough to move information, transfer information, and have an understanding about process and procedures for the work on the natural gas industry?”

That propagated the question and the discussions over the course of the next couple of years  — probably from ’93 to ’94 / ’95. It was found that although there was some training out there  — actually the code, Part 192 talked about training and some aspects of identifying how people do their work —  there really never was a formal rule in place.

The onset of that was organizations like PHMSA and the state NAPSA groups, the state chiefs of pipeline safety around the country and then organizations like the American Gas Association, the American Public Gas Association, NGA and so on got together with representatives to start putting together what this qualification or training rule might look like.

You want to be careful about aspiring or defining qualification as training because there’s different components to the qualification process. It’s not just the training rule.

Russel:  What are those components of qualification? Because I think a lot of people in the business kind of notionally understand OQ but don’t really understand how it came about and why it’s put together the way it’s put together, so maybe you could break down the components for us a little bit.

Mike:  Sure, thanks. I like to describe it as a four-legged stool that’s comprised of a knowledge-based component that has the ability for an individual to understand the procedure and to be able to process that procedure while it’s being used in the field or in their daily work activities.

There’s a skill component, or a skill leg that says I have to be able to not only understand the procedure, but I have to be able to apply it. The ability piece, the third leg of the stool would be I have the knowledge, I have the skill, now I have to demonstrate my ability to perform that procedure —  or as the code calls it, “a covered task” — on a pipeliner/pipeline facility.

I have to be able to demonstrate that ability given that knowledge, skill, and ability to do that, once I’ve identified that, I have to be able to identify abnormal operating conditions that may transpire around a procedure or covered task while it is being performed.

I have to know what’s not right, and I have to understand that and be able to take corrective actions to make sure that the procedure is done correctly.

Russel:  I grew up as a measurement guy. I started out in the business in measurement. The idea of having knowledge, having skill, and having the ability to perform that skill, that, to me, is pretty linear. It’s kind of step-by-step.

When you start talking about the ability to recognize and respond to an abnormal condition, that starts getting exponentially more complex, at least in my experience.

Mike:  As you apply  — as an operator or an individual representing an operator on the pipeline —  those skills and abilities, part of the knowledge-based component that you gain in understanding those procedures is the recognition of what those AOCs may be —   if I can use that acronym, the AOCs — around the procedure that you are actually performing.

It isn’t something that you just blindly walk into. It’s part of the knowledge-based component of the process in identifying and understanding those. Then, in your ability testing, or the evaluation of your skills, that component is listed as a criteria for being able to pass or to be able to perform that covered task correctly.

Before you actually perform as a qualified operator in the field, those abilities to understand and react  — the terminology is “recognize and react” — to an AOC in the field is well-honed and well-schooled through your evaluation process in being qualified to perform that covered task.

Russel:  What kinds of things were initially covered as the OQ Rule was being put into place, and how has that expanded over time?

Mike:  Just to make sure that the audience understands, the OQ Rule went into effect — operation qualification became effective in the late ’90s. It is a mature rule by definition. It’s been out there 20 years. There’s been some changes to it, but not really significant.

If you go back and look at what the federal code outlines as a requirement for performance of an operator qualification process, it centers around a four-part test that the operator applies to determine if what the functionality is that the individual’s working on is a covered task.

That four-part test, it reads straight out of the code. Is it performed on a pipeline facility? Is it an operation or maintenance task? Is it performed as a requirement of the part? In other words, Part 192 gives you the guidance for operation of a pipeliner/pipeline system. Finally, does it affect the operation or integrity of the pipeline?

If you answered yes to all those questions, you’re performing a covered task, and the qualification of that individual performing that task is required as part of the regulatory activity followed by the operator.

Russel:  This may be a little bit out in right field, you know, my experience tends to be more around the control room, and I tend to think of operator qualification as those things that we’re doing in the field physically on the pipeline. Am I missing something or is that…?

Mike:  Well, the operator qualification piece encompasses all of the activities that are found in Part 192. Control room management certainly has its own separate set of requirements and procedures and processes to follow.

Ingrained into the actual qualification rule itself is  — let’s use for instance a control operator. If they’re performing a function that is answered yes by all four of those questions then they would need to be qualified in that task that they are performing, in addition to the regulation that they’re following under control room management.

To your point, a high number or a high percentage of the tasks performed are by nature in the field. That’s where the majority of the work is done.

Remember one other thing  — and maybe we’ll get into this a little bit later  — these procedures apply to the operator as well as the contractor who is doing work for the operator, and there’s a few nuances regarding that.

If we have a chance to explore that in a little while, I think that’d be a good piece of the conversation.

Russel:  Yeah, we can migrate right to that now if you like. I always try to simplify these things. It’s so easy for those of us that work in a particular discipline to get used to and understand our own jargon, and I try to break that down and get it outside of the jargon and get it into normal language.

I want to try to state this in normal language, knowing that it’s not exactly what’s in the code. Basically, I need to be qualified for anything that I’m going to do related to operating or maintaining a pipeline.

To be qualified, I have to have knowledge, skills, and the ability to do the task in a way that I can see when the task is going sideways and correct it. Is that correct?

Mike:  No, you’re correct. You’ve summarized it very well and used the language that is appropriate to the definition of operator qualification.

One thing I would say, the rule itself never addressed new construction activities on a pipeline system for an operator. The original rule did not. Remember that it centers on operation and maintenance tasks.

However, over the course and the maturity of the rule, there has been a lot of discussion about inclusion of new construction into the activity base for qualification. In fact, two states have gone forward and required new construction to be considered for qualification process. Ohio and California have led that charge.

Over the years though, that’s been a point of discussion on how new construction is affected by the activities of individuals putting the pipeline in the ground.

Russel:  From my standpoint, given how important construction, and in particular, all the record-keeping around construction is for the life cycle, maintenance, and operation of a pipeline, I think it’s pretty easy to make the case that, you ought to be qualified for doing those tasks as well.

Mike:  There certainly is people that are on that side of debate or folks with that opinion. There are a lot of processes found within Part 192 that require testing and documentation of the pipeline before it becomes active and delivers the molecules of gas to the end-user.

You’re right, there’s a lot of folks who talk about new construction being added. Then on the other side of the debate are the folks that say, “We already have mechanisms in place by the code that requires testing and validation of the pipeline serviceability before it becomes effectively an agent of transferring energy.”

Again, the debate moves on. The rule hasn’t changed to include new construction, but states have taken action to include that.

Russel:  Let’s talk a little bit about contractors because you were talking about how this applies to contractors as well. In my simple-minded definition, I said anyone who’s going to do something on the pipeline, and that certainly would include contractors.

Mike:  I appreciate what you’re saying. Operator qualification is not a difficult concept. It is pretty straightforward. It says that the operator who has procedures for performing work on the pipeline has to apply those procedures through knowledge, skill, and ability evaluation.

That goes for the contractors who are working on that pipeline system for that operator. They need to be qualified in the operator’s procedures, or they have to be able to include their own procedures into the operator’s O&M manual, so that they can be accepted by the operator as a performance of a covered task on items that they qualify to.

Again, the contractor has to be qualified for the operator’s procedures and follow the same process that is done by the operator.

Russel:  You mentioned earlier that this is a mature rule, and it’s been around for a couple of decades. What’s the status of the rule now in terms of how it’s being adopted and utilized? Maybe you can talk to that a little bit.

Mike:  It has been adopted by all the operators that are in the U.S. They have to follow the procedures and follow the regulation in order to work on the pipeline system, provide natural gas to their customers.

The future holds some opportunity for maybe inclusion of new construction as a criteria of the rule itself, making sure that the new generation of pipeliners that are coming on — as the baby boomers exit — to perform those functions are well trained and well qualified to perform those covered tasks as their predecessors have been exposed to.

I find that as I go around the country and work with companies that the focus on assuring the qualification of the individual is significant, that there are locations and test locations and site locations that have been set up that mimic the operational process of an operator in the systems that they own, and that they train to those before they actually put folks out on the pipeline.

I don’t think that on the job training is dead. I think that will always be a component of learning the industry. For what it’s worth, giving somebody a shovel and say, “Dig that ditch, so we can put that pipe in there,” is probably a pretty good way to determine how an individual will perform in the field or over the course of a career.

Giving them the knowledge and the skill and the evaluation ability to perform those tasks as they grow in the industry, I think is an important concept that needs to be continued by the operators and the contractors around the country.

Russel:  Yeah, I think that’s absolutely right. It’s kind of radical when you think back 20 years ago or longer when most of the training was on the job training. It was kind of passed down.

If you’re a person that studies safety and you study safety performance, tribal knowledge is always problematic because you don’t see how the knowledge transfer changes over time. I think what OQ does, one of the things it does is it establishes some standards and some baselines for what is the knowledge and what is the transfer.

Mike:  It does.

Russel:  That’s a very important aspect of this, but it’s not the only thing.

Mike:  No, and I agree with you. It establishes that formal process that goes on. Just my own opinion is the gentleman that taught me about natural gas probably forgot more than I’ll ever know. He was a good man, and he helped a lot of folks acclimate to how natural gas works and the properties around it and the functionality of a pipeline system.

There wasn’t a formal classroom training. That’s what’s changed is that it’s moved from the field into the classroom.

Russel:  Yeah, and classroom is an important aspect of it. In our measurement training company, we use to do training on live gas. One of the things that was always interesting to me when you brought in a brand new, green technician and you had them working on a meter on their desk, that’s all very interesting and you can learn a whole lot.

When you walked outside and you’re going to blow down a 325 psi piece of pipe, that’s a whole different experience than working on the bench. There’s an aspect of this where the OJT (on-the-job training) is important. You’ve actually got to see how these things actually work in practice and get some experience with that.

Mike:  Couldn’t agree more. You blow down that size of pipeline, it’s like standing next to a jet engine for a little while.

Russel:  It is.

Mike:  It will make a believer out of you in a hurry.

Russel:  It will. For some people, 325 psi is not that much pressure.

Mike:  No, that’s service delivery. [laughs]

Russel:  This is kind of a funny side story. I was doing a project many years ago with a group that was doing natural gas capture off of trash facility, a dump basically.

They were capturing the methane off of that and they were talking about the high pressure and the low pressure side of their compressor. I’m like, “Well, how high is the high pressure side?” They go, “Oh, it’s 20 psi.” I’m like, “What?”

[laughter]

Russel:  Yeah, well, it’s all relative, right?

Mike:  Everybody has their position, that’s for sure.

Russel:  It’s all relative to your experience, right?

Mike:  That’s right.

Russel:  Part of it. If I’m a person who kind of doesn’t know what operator qualification is and I was trying to put a program in from scratch, what would be your advice?

Mike:  First, become familiar with the section of the code, Title 49, Code of Regulations, Part 192, Subpart N, Qualification of Pipeline Personnel. Read that, understand it. Read the interpretations that are found on the federal website at the PHMSA website.

The second thing I would do is address your state regulatory body to find out if there’s any nuances that the state has integrated into the qualification of pipeline personnel as part of the regulations to adhere to as an operator.

Third, I would talk to individuals who have backgrounds in the qualification field. There are a number of very good ones around the country who have spent the better part of two decades defining and understanding how OQ works, how qualification of an individual goes beyond sitting in a seat in a classroom and looking at PowerPoints for eight hours, and how they have integrated the skill and ability testing into the knowledge base of those procedures.

Russel:  That sounds all very straightforward.

Mike:  [laughs] It’s not a difficult rule. It just takes a little time to enact. It is a pretty straightforward rule.

Russel:  I’m guessing you’ve done this once or twice before because that all just flowed right off your tongue like you’ve done it a hundred times.

Mike:  You’ve got to be prepared for the elevator speech. You never know when you get use it.

[laughter]

Russel:  Ha, so true. So very true. Michael, look, I appreciate you coming on the podcast. Before we wrap up, how would somebody get in touch with you if they wanted to ask you questions or reach out for some help on their OQ program?

Mike:  The easiest way is to call me on my cell phone, 480-250-0241. My email address is mcomstock1@cox.net. The company that my business partner and I own is called C&M Regulatory Pipeline Consultants, and we’re in Tempe, Arizona.

Russel:  Great. You guys obviously work on the gas side, and of course, there’s OQ issues for the liquids guys too. It’s not just the gas guys that get to deal with this. Do you ever do any work on the liquid side, or are you pretty much just a gas guy?

Mike:  Yes. Robert Miller is my business partner. Robert is the former chief of pipeline safety and the manager of the pipeline safety program for the State of Arizona. We have a pretty wide and varied background when it comes to this process. We collaborate whether we’re on natural gas pipelines or the liquids that are out there as well.

Russel:  Okay, well, great. Look again, thanks for coming on. And I appreciate it. I certainly learned a few things. I think I actually understand a little bit about what OQ is and maybe even a little bit about how to go about doing it, so I appreciate you coming on.

Mike:  Perfect. It was an honor. I appreciate you asking me to be on.

Russel:  I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Mike Comstock. Just a reminder before you go, you should register to win our customized, Pipeliners Podcast YETI tumbler. Simply visit pipelinepodcastnetwork.com/win to enter yourself in the drawing.

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