Should operators implement measures to ensure that the procedures on which qualification is based are consistent with the actual practices implemented in the field?
A major purpose of the operator qualification rule is to eliminate job performance errors that might affect the integrity of pipeline systems. Such errors can be inadvertent (e.g., forgetting a step in implementation of a procedure) or systemic (e.g., practices that are inconsistent with written procedures, such as purposely ignoring SCADA system alarms because they are known to be inaccurate). Elimination of systemic errors is as important as eliminating inadvertent ones. Therefore, operators should incorporate into their qualification program provisions for ensuring that practices in the field are the same as those documented in the operators O&M Plan, which provide the basis on which persons are qualified. Such provisions might include field audits of on-the-job performance by separate audit units within the company.
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