# Small Natural Gas Operator OQ Guide - January 2017 (PDF)

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- **citation:** PHMSA Guidance, Small Natural Gas Operator OQ Guide - January 2017 (PDF)
- **title:** Small Natural Gas Operator OQ Guide - January 2017 (PDF)
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- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
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- **summary:** Small Natural Gas Operator OQ Guide - January 2017 (PDF) Document Small_Natural_Gas_Operator_Operator_Qualification_Guide_(January_2017).pdf (2.85 MB) This guidance material was implemented under the sponsorship of the U.S. Department of Transportation. The material relies on sources representing the best opinion on the subject at the time of publication. However, it should not be assumed that all acceptable safety m
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Small Natural Gas Operator OQ Guide - January 2017 (PDF)

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 Small_Natural_Gas_Operator_Operator_Qualification_Guide_(January_2017).pdf (2.85 MB)

        This guidance material was implemented under the sponsorship of the U.S. Department of Transportation. The material relies on sources representing the best opinion on the subject at the time of publication. However, it should not be assumed that all acceptable safety measures and procedures are mentioned in this manual. The reader is referred to the Code of Federal Regulations (49 CFR Parts 190-199, Part 40 and also NFPA 58 & 59) for the complete pipeline safety requirement.

          Effective Date: Sunday, January 1, 2017

<<<PAGE 1>>>

Operator Qualification Guide
for
Small Distribution Systems
January, 2017
United State Department of Transportation
Pipeline and Hazardous Materials Safety Administration
Office of Pipeline Safety

<<<PAGE 2>>>

ACKNOWLEDGEMENTS
The Small System Operator Qualification Guide Material Project was part of a national effort
initiated by the United States Department of Transportation, Pipeline and Hazardous
Materials Safety Administration, Office of Pipeline Safety.
In April of 2003, a team of individuals representing the liquid pipelines, natural gas
industry, and regulatory representatives from around the country, were tasked with
development of guidance for small system operators of liquid and natural gas systems, to
comply with the Operator Qualification (OQ) Rule. The Small System Operator Task Force
(SSOQ) in this document has developed:
 A list of definitions which may be helpful in understanding the OQ Rule,
 Model plan for compliance to OQ Rule,
 A “How to Guide” to comply with OQ,
 Guidance material which explains OQ audit protocols.
The following SSOQ members are recognized as experts in their fields and have given
generously of their unique knowledge. They were directly involved in the development of
this guide material:
Richard G. Marini – Co-Chair – New Hampshire – Regulatory
Michael Comstock – Co-Chair – City of Mesa, Arizona – Municipal
Bert Kalisch – American Public Gas Association
Daren Gilbert – California Regulatory
Dave Hraha – Iowa Municipal Organization
Don Stursma – Iowa Regulatory
Glen Tong – California Regulatory
Jim Hotinger – Virginia Regulatory
John Gawronski – OPS Consultant – Regulatory
Ken Taylor – White Mountain Oil Company – Liquid
Lane Miller – Transportation Safety Institute – Regulatory
Mike Bostic – Dennbury Company – Liquid
Massoud Tahamtani – Virginia Regulatory
Phil Bennett – American Gas Association
Rudy Parcel – Iowa Municipal Organization
John Erickson – American Public Gas Association
This guidance material was implemented under the sponsorship of the U.S. Department of
Transportation. The material relies on sources representing the best opinion on the subject at
the time of publication. However, it should not be assumed that all acceptable safety
measures and procedures are mentioned in this manual. The reader is referred to the Code of
Revised January, 2017 i

<<<PAGE 3>>>

Federal Regulations (49 CFR Parts 190-199, Part 40 and also NFPA 58 & 59) for the
complete pipeline safety requirement.
Included in the 2012 Cooperative Agreement between PHMSA and the APGA Security and
Integrity Foundation was the task to update and/or revise the 2002 PHMSA Small Operator
OQ Guide. A cross section of industry subject matter experts (SME) were identified and a
team was created to review the original guide. The following were members of the SME team
for this project and their input was invaluable:
John Erickson – Chair - APGA Security and Integrity Foundation (SIF)
Gerry Lee – Project Manager – APGA SIF
Bill DeFoor – Municipal Gas Authority of Georgia
Matt Smith – Illinois Commerce Commission
Rich Medcalf – Indiana Utility Regulatory Commission
Warren Matlock – APGA Security and Integrity Foundation
Ed Hawthorne – City of Enumclaw
Gary Worland – Citizens Gas
Judy Ramsey – Alabama Public Service Commission
Dave Hraha – Iowa Association of Municipal Utilities
Rick Marini – APGA Security and Integrity Foundation
Steve Anthis – Citizens Gas
Patti Johnson – Washington Utilities and
Tim Franklin – Municipal Gas Authority of Georgia
Darin Burk – Illinois Commerce Commission
Steve Carter – Athens Utilities
Chris Cawley – Municipal Gas Authority of Georgia
Nick Polley – Citizens Gas
Terry Roach - City of Carrollton Utilities
Wiley Walker – Mississippi Public Service Commission
Todd Brady – APGA Security and Integrity Foundation
Nathan Solem – South Dakota Public Service Commission
Revised January, 2017 ii

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CHARACTERISTICS OF A SMALL SYSTEM OPERATOR
All stakeholders in the pipeline industry fully support the operator qualification (OQ)
protocols developed by the U.S. Department of Transportation’s Pipeline and Hazardous
Materials Safety Administration (PHMSA) in response to the Pipeline Safety Improvement
Act of 2002. It is also recognized there is a need for effective guidance for small system
operators (i.e., those with less complex gas distribution systems) about how to comply with
the protocols. In response to this need, federal and state pipeline safety regulators as well as
representatives of small systems committed to develop that guidance and a set of criteria to
assist operators who operate less complex pipeline systems.
The one constant and underlying goal of the group developing the characteristics of a small
system operator, and their protocols, was to ensure that the level of safety provided by
PHMSA’s OQ process was maintained and the effectiveness of the OQ rule was not
compromised.
The fundamental rationale for having a different set of criteria for small system operators is
that many of these operators have a less complex system and management structure.
Therefore, such an operator does not need many of the processes and formal management
structure described in the current OQ protocols. Both pipeline safety regulators and the
regulated industry need to share a common understanding of the “general characteristics” of
a small system operator to ensure appropriate protocols application during a compliance
audit.
A number of system characteristics were discussed by the government-industry
team in determining—what is a “small system operator?” To provide general
guidance, two characteristics are discussed below.
1. Resources. Smaller systems have fewer resources available than larger systems;
however, all operators must comply with the same pipeline safety regulations.
Smaller systems have:
(i) Less complex systems than larger operators;
(ii) Fewer individuals;
(iii) Less complex management structures;
(iv) Few layers of management, if any, between the OQ Plan Administrator
and its personnel performing covered tasks.
2. Number of employees performing covered tasks. While this is part of
Characteristic 1 above, the government-industry task force agreed that a system
with five or fewer individuals performing covered tasks is likely to be a “small
operator.” The government-industry task force also agreed that, depending on other
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relevant factors, a system with more than 10 individuals performing covered tasks
could be determined to be a “small operator.”
These factors are not exclusive in determining a “small operator.” It is important to remember
guidance material which applies to large operators also applies to small operators. In
providing this supplemental guidance for small operators, the team recognized that the state
program managers have the authority and must also have the flexibility in making that final
determination in a fair consistent manner.
Again, the elements of OQ compliance should be the same regardless of size; none of
PHMSA’s criteria has been eliminated. The small system operator’s protocol elements have
been structured to reflect that smaller operators require less formal and less complex OQ
compliance program.
Revised January, 2017 iv

<<<PAGE 6>>>

TABLE OF CONTENTS
CHAPTER I – GUIDELINES FOR DEVELOPING AN OPERATOR QUALIFICATION
PROGRAM I-1
CHAPTER II – DEFINITIONS II-1
APPENDIX A – INDUSTRY RESOURCES A-1
APPENDIX B – SAMPLE OQ PLANS B-1
v

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CHAPTER I: GUIDELINES FOR DEVELOPING AN OPERATOR
QUALIFICATION PROGRAM
CONTENTS
ACKNOWLEDGEMENTS ............................................................................................................. i
CHARACTERISTICS OF A SMALL SYSTEM OPERATOR .................................................... iii
CHAPTER I: GUIDELINES FOR DEVELOPING AN OPERATOR QUALIFICATION
PROGRAM ................................................................................................................................... I-1
Introduction ............................................................................................................................... I-3
Preparing a Written Operator Qualification Plan ...................................................................... I-3
Identify Covered Tasks ......................................................................................................... I-4
Evaluate Individuals Who Perform Covered Tasks .............................................................. I-6
Allow Unqualified Individuals To Perform A Covered Task If Directed And Observed By
An Individual Who Is Qualified ........................................................................................... I-8
Post Accident/Incident Evaluation ........................................................................................ I-8
For Cause Evaluation ............................................................................................................ I-9
Communication of Changes .................................................................................................. I-9
Establish Re-evaluation Intervals ......................................................................................... I-9
Training ............................................................................................................................... I-10
Record Keeping .................................................................................................................. I-10
Record Retention ................................................................................................................ I-11
Contractors .......................................................................................................................... I-11
Record Keeping for Contract Personnel ............................................................................. I-12
Emergency Response .......................................................................................................... I-12
Resources ............................................................................................................................ I-12
CHAPTER II: DEFINITIONS .................................................................................................... II-1
APPENDIX A: RESOURCES
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APPENDIX B: MODEL OQ PLANS
APGA SIF Model OQ Plan
IAMU Model OQ Plan
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INTRODUCTION
These guidelines were prepared by a team of industry and government pipeline safety and
training experts to assist small operators and master meter system operators to develop programs
to ensure that individuals who operate and maintain these systems are qualified for the work they
perform. Operators are required to prepare and follow an OQ program by federal regulations at
49 CFR 192, Subpart N and 49 CFR 195, Subpart G, as well as regulations adopted by some
states.
OQ programs must identify each individual, whether they are an employee of the operator or an
employee of a contractor hired by the operator, who performs covered operations or maintenance
activities on the piping system. The OQ program must also identify the “covered tasks” that each
individual performs and ensure that each individual is evaluated to ensure they have the
necessary knowledge, skills and abilities (KSAs) to perform each task, as well as to recognize
and react to abnormal operating conditions (AOCs) that may arise while performing these tasks.
The process the operator follows to accomplish these objectives must be in writing. Records of
the tests, evaluations, and other actions required in the plan must be made available for
inspection by state and federal pipeline safety inspectors.
The following steps should be considered when preparing an OQ program.
PREPARING A WRITTEN OQ PLAN
The regulations require that you prepare and follow a written OQ plan that at a minimum
includes the following eight provisions:
1. Identify covered tasks (operations and maintenance (O&M)) activities affecting the
integrity of the pipeline and required by the safety code);
2. Evaluate individuals performing covered tasks to demonstrate that they are qualified;
3. Allow individuals who are not qualified to perform certain covered tasks if directed
and observed by an individual who is qualified;
4. Evaluate an individual if there is reason to believe that the individual's performance
of a covered task contributed to an incident;
5. Evaluate an individual if there is reason to believe that the individual is no longer
qualified to perform a covered task;
6. Communicate changes that affect covered tasks to individuals performing those
covered tasks;
7. Establish re-evaluation intervals; and
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8. Describe how training will be used in the OQ program where appropriate (new hires,
refresher training for existing employees who transfer to new jobs or fail re-
valuations, etc.).
In addition to these minimum requirements, the written OQ plan should:
1. Name the person/position who will be responsible for ensuring that the requirements
of the plan are carried out;
2. Identify records necessary to carry out the plan and where those records will be kept.
IDENTIFY COVERED TASKS
A covered task is defined as any task that:
1. Is performed on a pipeline facility;
2. Is an operations or maintenance task1;
3. Is performed as a requirement of this part (Part 192 or Part 195); and
4. Affects the operation or integrity of the pipeline.
The first step in identifying covered tasks is to identify tasks performed on pipeline facilities.
“Pipeline facilities” means all underground and aboveground piping; it generally does not
include piping inside customer buildings, although if gas is sold to the customer through a gas
meter located inside the building, “pipeline facility” extends inside up to the outlet of the meter.
A good source to identify tasks performed on a pipeline facility is the Manual for Operations,
Maintenance and Emergency Response. This will describe O&M tasks performed on a system.
The following is a list of common O&M tasks. Not all of these tasks may apply to every system,
and there may be additional tasks performed on other systems that meet the definition of a
covered task that are not listed here:
Investigating leak/odor complaints,
Locating and marking lines,
Controlling and monitoring pipeline pressures and product flows,
Operating an odorizer,
Monitoring natural gas odorization levels (“sniff tests”),
1 Note: Some states include new construction as covered tasks
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Repairing leaks,
Inspecting and testing pressure regulator station and overpressure protection,
Tapping pipelines under pressure,
Conducting leakage surveys,
Joining pipe for maintenance,
Inspecting critical valves,
Welding on a pipeline for maintenance,
Excavating and backfilling,
Repairing coating on existing steel pipelines,
Measuring pipe-to-soil potential,
Coating aboveground piping,
Inspecting for atmospheric corrosion,
Inspecting the condition of exposed pipe or pipe coating,
Installing/replacing a rectifier,
Installing/replacing an anode or test station,
Inspecting a rectifier,
Visually inspecting for internal corrosion,
Purging,
Patrolling,
Isolating sections of pipe or stopping off or otherwise controlling the flow of gas or
product to a work site.
Certain critical tasks fall outside the scope of the OQ Rule. Relighting appliances and other work
performed on gas piping or equipment inside the residences are not covered tasks since they are
not performed on a pipeline facility as defined above. Conducting meter dial tests for leaks of
internal piping also fall in this category. While individuals performing these tasks are not subject
to the OQ program, operators should ensure that competent people to do this work since mistakes
can lead to accidents. OQ does not exempt anyone from the general good business practices to
use competent individuals for all tasks that are important for the safe operation of your system.
Covered task lists may also be purchased from many industry trade associations and other
vendors. If one of these lists is utilized, it must be carefully reviewed to ensure that it includes all
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the tasks performed on the system. Any tasks that are not performed on your system should also
be deleted.
EVALUATE INDIVIDUALS WHO PERFORM COVERED TASKS
Evaluating means testing a person through written tests, oral exams, observation while
performing the task on the job or in a classroom or simulated setting, or any other documented
method or combination of methods that can prove the individual possesses the necessary KSAs
to perform the covered task and recognize and react to AOCs.” A checklist is required if
observation on the job or a simulation is used for evaluation. To be acceptable, each evaluation
must include a document that states what is pass or fail for each step in the evaluation and
indicates what knowledge, skills, abilities or AOC’s were tested or observed.
An OQ plan must list the specific evaluations (tests, observations, etc.) that will be accepted as
evidence of qualification in each covered task. The list may include more than one acceptable
means of qualifying individuals for a task. For example: An operator may adopt their
contractors’ evaluations or evaluations by third parties (e.g., associations, vendors, state and
local governments) however the operator is responsible to show that the evaluations are
appropriate for the way the task is performed on the system.
The operator should be able to demonstrate that the evaluations accepted for each covered task
measure the KSAs required for the task. The evaluations should address critical skills and
abilities in addition to critical knowledge needed to perform each task. For example, certain tasks
require physical abilities and physical skills critical to accomplishing the covered task, in
addition to knowledge of how to perform the task. In that instance, it must be ensured the
evaluation includes a test to address the physical ability of the individual to perform the task. The
actual evaluation may involve a knowledge-based test, plus a practical application in the field or
classroom simulation to demonstrate physical ability and proficiency.
Further, the testing for covered tasks included in the qualification program must also include
questions or hands-on demonstrations on AOCs associated with the task to both recognize and
react to the AOCs. Abnormal operating condition means a condition that may indicate a
malfunction of a component or deviation from normal operations that may:
(a) Indicate a condition exceeding design limits; or
(b) Result in a hazard(s) to persons, property, or the environment.
For example, a leaking gas pipe is a malfunction of the pipe (it’s not supposed to leak) and can
result in a hazard to persons and property.
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Some typical AOCs as identified in American Society of Mechanical Engineers (ASME) B31Q
Pipeline Personnel Qualification include:
Unplanned escape of gas from a pipeline,
Fire or explosion,
Unplanned pressure deviation,
Unplanned flow-rate deviation,
Pipeline damage,
Activation of a safety device other than during planned testing,
Unplanned status change,
Interruption or failure of communications, control system or power,
Inadequate odorization or reports of gas odor.
Some AOCs are specific to certain covered tasks (e.g., unplanned pressure deviation could be
caused by the failure of a valve, regulator, relief valve, etc., depending on the task). Other AOCs
are general and apply to many, if not all, tasks (e.g., anyone performing operations or
maintenance tasks should be able to recognize and react to gas odors, leaking product or spills).
Operators must determine credible AOCs and identify how personnel are expected to react to
these. Evaluations used by the operator should address how to recognize and react to abnormal
operating conditions. AOC evaluations may be broken out into a separate section of the
evaluation or may be incorporated within those portions of the evaluations that address routine
KSAs. Operators should be able to demonstrate that all AOCs that can reasonably be anticipated
to be encountered and related to the task being performed are addressed in the evaluations for
that task, particularly if off-the-shelf evaluations are being used.
Some conditions such as recognizing low pipe-to-soil potentials or corroded pipe could be
considered AOCs or could be considered part of the routine KSAs for covered tasks such as
measuring pipe-to-soil potentials or inspecting pipe condition. For OQ compliance purposes, as
long as the evaluations for the covered task address how to recognize and react to these
conditions, it does not matter if these are classified as AOCs or normal conditions.
If an operator elects to accept evaluations developed by others, e.g., your contractors, state
plumbers’ licenses, associations or other vendors, that operator must ensure that these
evaluations address the KSAs necessary to perform the task and recognize and respond to AOCs
according to procedures.
While not specifically required by the regulation, the written OQ plan should address the
credentials of the individuals who will evaluate your employees and contractors. If the
evaluations chosen require the evaluator to make a judgment whether the task was performed
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correctly, then the evaluator should possess adequate knowledge about proper performance of
the task so that a proper judgment can be made when evaluating the task.
ALLOW UNQUALIFIED INDIVIDUALS TO PERFORM A COVERED TASK IF
DIRECTED AND OBSERVED BY AN INDIVIDUAL WHO IS QUALIFIED
Operators may allow individuals who have not met the evaluation criteria listed in the OQ plan
to perform certain covered tasks under controlled conditions. A written OQ plan must spell out
the conditions under which individuals who have not met the qualification criteria may perform
tasks while under the observation and direction of a qualified individual. This is intended to
allow on-the-job training and temporary labor work teams. The operator must ensure that non-
qualified personnel are watched by a person qualified in the covered task being performed and
the observer should be prepared to take immediate corrective action should he/she observe work
being done that is not in accordance with the operator's procedures, or is being done in an unsafe
manner. Supervising from a remote location is NOT acceptable – the qualified individual must
be on-site, watching the task and ready to intervene immediately should it be necessary. The
written OQ plan should provide guidance on how many non-qualified workers can be directed
and observed at one time by a qualified individual and a list of any tasks non-qualified persons
will not be allowed to perform (e.g., hot taps).
Operators may specify in the OQ plan that only qualified individuals may perform covered tasks,
in which case on-the-job training for covered tasks may not be used even with a qualified
individual directing and observing the non-qualified individuals.
POST ACCIDENT/INCIDENT EVALUATION
The OQ plan must specify that the operator will re-evaluate anyone whose performance of a
covered task may have contributed to an accident (for hazardous liquid pipelines) or incident (for
gas pipelines), either caused it, failed to respond appropriately or made it worse by responding
inappropriately. For example, if an accident/incident occurs because a pipeline location was
inaccurately marked, the individual who marked the line may have contributed to the
accident/incident. Similarly, if an individual opens a valve that should remain closed and that
causes an accident/incident to be worse, that contributes to the severity of the accident/incident.
The OQ plan must specify the process used to re-evaluate these individuals. Re-evaluation need
not be by the same methods you used to initially evaluate the individual, but if the operator
intends to use a different method, this method must:
Address the KSAs and AOCs for the task, and
Be listed in the written OQ Plan as an accepted evaluation for the covered task.
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FOR CAUSE EVALUATION
The OQ plan must include provisions on how to re-evaluate persons for whom there are reasons
to believe that they are no longer qualified. The plan should include some guidance for
supervisors to recognize and react to behavior that would trigger these provisions. Reasons could
include observation of the person not following procedures, injury or illness that reduces motor
skills.
COMMUNICATION OF CHANGES
The OQ plan must specify how changes to policies, procedures, equipment or regulations are to
be communicated to anyone who performs covered tasks affected by the change. Re-evaluation
may be required if the changes affect the KSAs required for the task. For example, when
purchasing a new leak detection instrument, an operator should consider whether the new
instrument is basically the same as the old instrument it replaces, in which case you need only
communicate to the persons using the device that it has been replaced. If, however, the new
instrument operates on a different principle than the one it is replacing, it may be necessary to
retrain the persons using it and document this training. The OQ plan should also spell out
conditions under which re-evaluation will be required such as when changes to policies,
procedures, etc., require it.
ESTABLISH RE-EVALUATION INTERVALS
To continue to be qualified, individuals performing covered tasks must be periodically re-
evaluated. Re-evaluation intervals should be based on factors such as:
1. How frequently is the covered task performed? More frequent performance may
justify longer re-evaluation intervals;
2. How complex is the covered task? More complex tasks may require shorter re-
evaluation intervals; and
3. What might the consequences be if the task is performed improperly? What is the
worst that could happen if the covered task is not performed correctly, with
“catastrophe” justifying shorter re-evaluation intervals and “nothing” justifying
longer intervals?
Three years is the commonly accepted interval for most tasks. Intervals over 5 years will require
justification. Tasks that are performed infrequently may require re-evaluation prior to
performance. Federal/state regulations require re-evaluation for certain covered tasks such as
pipe plastic joining and welding to be conducted at annual intervals.
Re-evaluation need not be by the same process as initial qualification but must address the
knowledge, skills, abilities and AOCs for the task.
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TRAINING
The OQ plan should describe how training fits into an operator’s OQ program. While
qualification is accomplished through evaluation, not training, some individuals will require
training to provide them with the KSAs necessary to pass the evaluations for a covered task.
Some examples of individuals requiring training are:
1. New hires,
2. Individuals taking on new tasks (transferred or promoted),
3. Individuals who fail one or more evaluations,
4. Infrequent performance of a covered task,
5. Post Incident or for cause re-evaluation.
This does not mean that every individual who performs a covered task needs to go through a
training program before the individual can be re-evaluated. In fact, a common misconception is
that training counts as evaluation for a task. Attendance records, certificates of completion, etc.,
from training classes are not evaluation records and cannot be used as the basis for qualifying an
individual for any task. Where a training course includes written or oral exams, observations on-
the-job or in a classroom simulation it is the records of these exams and/or observations that can
be counted as evaluations for a covered task as long as they address the knowledge, skills,
abilities and AOCs for the task. Records of written or oral exams alone cannot serve as an
evaluation because the written or oral exam can’t determine ability.
RECORD KEEPING
An operator must maintain records to prove that the written OQ plan is being followed. For each
individual who performs a covered task on your system, an operator must be able to produce a
record of the date the individual passed each evaluation required for each covered task the
individual performs, the tasks for which the individual is qualified and the method used to
qualify the individual. Records of re-evaluations for cause, post incident and when required by
re-evaluation intervals must also be maintained. The method may include any combination of
written or oral tests, observation in classroom, on-the job or simulation, or other methods
specified in the OQ program as accepted for the covered task. An operator should be able to
provide federal or state inspectors with copies of the evaluation methods, e.g., tests or
observation checklists used to qualify a person for the task, so that the inspector can determine if
the evaluations address the appropriate KSAs for the covered task. You can make an inspection
easier on both you and the inspector by having a list of the knowledge, skills, abilities, AOCs and
identifying where each is addressed in your observation checklists, test questions and other
evaluation tools.
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RECORD RETENTION
Records must be maintained for 5 years after the evaluation is no longer required for current
qualification for any covered task. In other words, the record retention period is 5 years PLUS
the re-evaluation interval specified in an operator’s OQ plan for the covered task. For example, if
an operator has a 3-year re-evaluation interval for a covered task, and an individual passes an
evaluation on October 28, 2012, then re-passes the evaluation on October 28, 2015, the operator
must maintain the record of the October 28, 2012 evaluation until October 28, 2018, since the
date October 28, 2015, is the date on which the operator ceases to rely on the October 28, 2012
evaluation for qualification.
CONTRACTORS
Many operators use contractors to perform covered tasks on their pipeline systems. The OQ
regulation requires that any individual who performs a covered task on a pipeline system be
qualified for that task according to THE OPERATOR’S OQ plan. If an operator uses contractors
for any covered task, the operator is responsible to ensure that each contractor employee who
performs one or more covered tasks on your system is qualified for that task or is being directed
and supervised by a qualified individual (if the operator’s OQ plan allows for this).
Below are four approaches to handling contractor qualification:
1. Operator evaluates the contractor individuals using company evaluations.
2. Operator allows the contractor to evaluate its personnel using either the operator’s
evaluations for the tasks or the contractor’s evaluations for the tasks. In the latter
case, the operator should obtain copies of the contractor’s evaluations and ensure they
address the same knowledge, skills, abilities and AOCs as the operator’s evaluations
for the same tasks. Evaluations must be documented, e.g., test questions are written
and observation evaluations include checklists indicating what is observed. These
evaluations must be listed in the operator’s OQ plan as evaluations accepted for these
tasks.
3. Require the contractor to be evaluated by a third party (e.g., NACE, NCCER, etc.).
The operator should contact the third party, obtain copies of the evaluations and
verify that they address the same knowledge, skills, abilities and AOCs as the
operator’s evaluations for the same tasks. Evaluations must be documented, e.g., test
questions are written and observation evaluations include checklists indicating what is
observed. These evaluations must be listed in your OQ plan as evaluations you accept
for these tasks.
4. The operator must ensure that non-qualified contractor personnel are watched by a
person (operator or contractor personnel) qualified in the covered task being
performed and the observer should be prepared to take immediate corrective action
should he/she observe work being done that is not in accordance with the operator’s
procedures, or being done in an unsafe manner.
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RECORD KEEPING FOR CONTRACT PERSONNEL
If contractor personnel are used to perform a covered task, the operator must be able to produce
records that the contractor personnel are qualified for the covered tasks they perform. The record
requirements for contractors are exactly as described above for company personnel. The records
must indicate the date the individual was qualified, the task(s) for which he/she is qualified and
the method of qualification. The method must be a method listed in the operator’s OQ plan as
accepted under the OQ plan for the covered task(s) the individual performs.
Contractor qualification records can be kept by the operator, by the contractor or by a third party.
If the operator elects to have the contractor or a third party keep the records, ensure that there are
provisions for the operator to obtain the records should the contractor or third party go out of
business. The operator must be able to produce these records for review for up to 5 years after
the last date an individual performs a covered task on your system.
EMERGENCY RESPONSE
OQ requirements for emergency response are limited to that portion of the response performed
on the pipeline facility, rather than at offsite locations remote from the facility (e.g., deploying
booms miles away is not a “covered task”).
Fire departments and other public responders are not required to be qualified and (if not
qualified) must not perform covered O&M tasks on the pipeline facility.
All other individuals employed by the operator must be qualified to perform their assigned
covered tasks or must be under the direct observation of a qualified individual.
Covered emergency response tasks are those tasks listed in §§ 192.615(a) and 195.402(e) that
meet the four-part test specified in §§ 192.801 and 195.501.
RESOURCES
Included in Appendix A are links to several resources that can be used with the development and
implementation of an operator’s OQ program and assist in preparation for OQ inspections. These
resources can be used to assist in a self-assessment of an operator’s OQ programs to ensure that
the program addresses all the important components that the regulators expect to see in an
acceptable OQ program.
Appendix B references samples of existing OQ plans that can be revised by operators for their
OQ plans. NOTE: These existing plans must be adapted to accommodate the operator’s specific
policies and procedures for their system.
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CHAPTER II: DEFINITIONS
A number of terms contained in the OQ Rule and its implementation found in 49 CFR Part 192,
Subpart N and in Part 195, Subpart G, may be unclear and subject to different interpretations by
operators and regulatory representatives. The following definitions have been obtained through
consideration of gas and liquid pipeline regulations, dictionary definitions of a word or term,
operator OQ plans, or other sources.
ABILITY
The capacity to do or act, physically and/or mentally.
ABNORMAL OPERATING CONDITION (AOC)
As defined in §§192.803 and 195.503, abnormal operating condition means a condition identified
by the operator that may indicate a malfunction of a component or deviation from normal operations
that may:
(a) Indicate a condition exceeding design limits; or
(b) Result in a hazard(s) to persons, property, or the environment.
[Note: To be qualified, an individual must be able to properly perform assigned covered task(s) and
be able to recognize and react appropriately to any AOC that may (reasonably be expected to) be
encountered while performing the covered task – whether the condition arises as a direct result of
his/her work performance (e.g., be specific to the covered task being performed) or not (e.g., be
generic in nature, but still observable because the individual is present on site).]
ACCIDENT
As defined in §195.50, an accident is a failure in a pipeline system which there is a release of the
hazardous liquid or carbon dioxide transported resulting in any of the following:
(a) Explosion or fire not intentionally set by the operator.
(b) Release of 5 gallons (19 liters) or more of hazardous liquid or carbon dioxide, except that
no report is required for a release of less than 5 barrels (0.8 cubic meters) resulting from a
pipeline maintenance activity if the release is:
(1) Not otherwise reportable under this section;
(2) Not one described in §195.52(a)(4);
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(3) Confined to company property or pipeline right-of-way; and
(4) Cleaned up promptly;
(c) Death of any person;
(d) Personal injury necessitating hospitalization;
(e) Estimated property damage, including cost of clean-up and recovery, value of lost
product, and damage to the property of the operator or others, or both, exceeding $50,000.
ACTIVITY
A specific deed, action, function, or sphere of action.
AFFECTS THE OPERATION OR INTEGRITY OF THE PIPELINE
Any activity, or omission of an activity, that could directly or indirectly result in a hazard to persons,
property or the environment. As used in the safety context of the OQ rule, the phrase indicates
activities that could result in an AOC that in turn could result in an unsafe operating condition.
BENCHMARK
A standard of measurement or evaluation.
COMMUNICATE
To convey information about; make known; to reveal clearly.
COMPLIANCE
Activity(ies) in accordance with a rule.
CONTRIBUTED
Determined to be a factor.
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CONTRIBUTED TO
A judgment by designated operator personnel, that the action or inaction of an individual(s) was a
factor in the occurrence of an incident/accident.
COVERED TASK
As defined in §§ 192.801 and 195.501, a covered task is an activity, identified by the operator, that:
(1) Is performed on a pipeline facility;
(2) Is an operations or maintenance task;
(3) Is performed as a requirement of this part; and
(4) Affects the operation or integrity of the pipeline.
CRITERION
A standard upon which a judgment is based.
CURRENT
Belonging to the present time; now in progress.
DEMONSTRATE
Provide tangible evidence.
DETERMINE
To conclude after consideration, investigation, or calculation.
DIRECT
To take authoritative charge of or supervise; to control, order or command.
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DIRECT OBSERVATION
Observation of an unqualified individual(s) during the performance of a covered task by an
individual who is qualified to perform the task at hand. The observer must be in direct visual and
verbal contact with the individual(s) and must be able to take immediate and effective corrective
action if incorrect procedures or AOCs are observed.
DOCUMENT
Prepare a retrievable record.
EMERGENCY RESPONSE
Actions taken by the o
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