The Perils of Pencil Whipping

Pencil Whipping is a euphemism used to describe when workers, supervisors, safety managers and/or evaluators fill out pipeline operator qualification documents,  sometimes in great numbers, without actually conducting the evaluation (much less providing the critical feedback).

Why?  So many reasons! This is not about a blame game but more about failure to properly train those on the front lines of pipeline operator qualification.

It's the operators field superintendent's fault! Its the fear of PHMSA! It's the contractors fault! It's the third-party evaluator's fault.

In truth,  there is likely plenty of blame to go around and in the end the fact that a pipeline operator qualification  was falsified is "a" real problem. Lack of character is the serious isue. As in serious charges and fines can be levied.

Let's break this down.

Premise: ABC Operator Field Superintendent - He is responsible for communicating (in most cases) the required pipeline OQ requirements to the contractor.  He is likely not well-read in all aspects of OQ other than being threatened with heavy fines and/or imprisonment for OQ mistakes. So, he hands the entire ABC Pipeline OQ List of Covered Tasks at the contractor and says - pick what you guys "do" with no further follow up.

Result: Contractor may or may not choose all the critical OQ require for that specific job. If he chooses too many, then he ends up paying for far to much pipeline operator qualification.  If he picks too few, he may show up on a job with employees who are not qualified on critical tasks. Further,  if the Superintendent does not follow through and accepts "whatever" the contractor chose it can be a recipe for disaster (most of the time so he can say he did not make the OQ choices).

Premise: ABC Operator Field Superintendent - In this scenario is uber-sensitive to PHMSA's long reach so he over-assigns Pipeline Operator Qualification. In this scenario the OQ is assigned as a one-size fits all labor hands to welders helpers to welders to superintendents  - everyone gets everything!

Result: Contractors often do not feel like they can "push back" on the OQ assignments because they don't either don't want to look foolish/uneducated or they don't want to tick of the project manager. :::pencil whipping commence::::  

 There are a myriad of other "situations" where pencil whipping can be found and not the least of which are motivated by finances or the lack therof, especially with oil playing ping ping about the $25 to 30$ mark.

The realities are: 

1) If a third party provides you with a price for your required operator qualification that sounds too good to be true, guess what it is. RUN!

2) If you conduct "in-house" Operator Qualification. KNow the proper way to conduct and record it. If you are unsure reach out to the data provider you use OR contact a OQ consultant to help clarify the good practices from the bad practices.

3) Falsified Operator Qualifications can and DO lead to serious consequences:

190.229 Criminal Penalties (Generally)

 Any person who willfully and knowingly violates [the Gas Pipeline Safety Act]…or any regulation… shall… be subject for each offense to a fine of not more than $25,000 and imprisonment for not more than five years or BOTH.