Industry Evolution: Ensuring Program Effectiveness

One of the most important — and most often overlooked — aspects of a strong Operator Qualification program is measuring whether the program is actually working. PHMSA's current guidance on performance monitoring, including FAQs 5.1 and 6.1, addresses this. But the OQ NPRM goes much further, proposing mandatory program effectiveness reviews.

PHMSA's Proposed Program Effectiveness Requirements

Under the proposed 49 CFR 192.807 and 195.507, operators would be required to conduct an annual program effectiveness review — at least once per calendar year, and not more than every 15 months. This is a significant new obligation that will require operators to systematically evaluate whether their OQ programs are achieving their intended safety objectives.

The 13 Mandatory Effectiveness Measures

The NPRM proposes 13 specific measures that operators must assess as part of their annual program effectiveness review:

1. Number of covered tasks identified
2. Number of individuals qualified to perform covered tasks
3. Number of evaluations performed
4. Number of individuals who failed to qualify
5. Number of reevaluations performed
6. Number of individuals who were reevaluated and failed to qualify
7. Number of incidents involving covered task performance
8. Number of incidents caused by unqualified individuals
9. Results of performance monitoring
10. Results of audits of covered task performance
11. Changes made to the OQ program
12. Training provided to covered task performers
13. Feedback from covered task performers on program effectiveness

Industry Support

The Gas Pipeline Advisory Committee (GPAC) and Liquid Pipeline Advisory Committee (LPAC) both unanimously accepted the program effectiveness provisions. This consensus signals strong industry support for formalized effectiveness measurement.

Helpful Resources

ASME B31Q contains relevant guidance on OQ program effectiveness measurement. Operators who are proactive about implementing effectiveness measures now will be well-positioned when the Final Rule takes effect.

Questions about program effectiveness? Contact EWN — we're here to help.