5 Questions You Should Be Asking of Your OQ Plan

When was the last time you really questioned your OQ (Operator Qualification) plan? The 5 W's — Who, What, When, Where, and Why — are a great framework for evaluating the effectiveness and completeness of your program. Here's a breakdown of each.

Who?

Your OQ plan must address operators, individuals, and the persons responsible for administering and overseeing the program. This includes identifying which employees and contractors perform covered tasks and ensuring they are all included in your plan.

What?

Your plan should identify all covered tasks, establish the full OQ program, include contractors performing covered tasks, and communicate changes to all affected personnel. Knowing exactly what tasks are "covered" under 49 CFR 192 Subpart N and 195 Subpart G is essential.

When?

Qualification is required when individuals are newly hired, transferring to a new covered task, involved in an incident, fail an evaluation, or when there is reason to believe they are no longer qualified. Your plan must also define reevaluation intervals for all covered tasks.

Where?

Records must be kept and must be available to PHMSA inspectors upon request. Your plan needs to specify where qualification records are maintained and how they can be readily accessed during an inspection.

Why?

The ultimate reason behind all OQ requirements is to protect people and the environment, and to comply with federal regulations under 49 CFR 192 Subpart N and 195 Subpart G. A well-maintained OQ plan is your best defense against incidents and enforcement actions.

Ready to take a closer look at your OQ plan? Contact EWN today to learn how we can help.