Industry Evolution: New OQ Tasks

One of the most significant proposed changes in PHMSA's OQ NPRM is the modification to the definition of a "covered task." Understanding what constitutes a covered task — and which of your employees are performing them — is the foundation of any OQ program.

Changes to the Covered Task Definition

Currently, a covered task must meet a 4-part test . PHMSA's NPRM proposed simplifying this to a 2-part test . However, after review by the Gas Pipeline Advisory Committee (GPAC) and Liquid Pipeline Advisory Committee (LPAC), both committees voted to retain a modified version of the 4-part test rather than moving to the simpler 2-part test. This reflected industry consensus that the 4-part test, when properly applied, provides the right level of rigor.

New OQ Requirements for Gathering Lines

The OQ NPRM also proposes new OQ requirements for gathering lines. Currently, many gathering line operations are not subject to OQ requirements. The proposed rule would extend OQ obligations to certain gathering line operations, expanding the universe of covered tasks and covered employees for operators in the gathering segment.

OQ Compliance Requirements

Operators must have a written OQ plan that identifies all covered tasks, establishes qualification methods for each task, and includes reevaluation intervals. The compliance requirements are designed to ensure a documented, auditable approach to workforce qualification.

Span-of-Control

PHMSA proposed a 1:1 span-of-control limit for on-the-job training scenarios. The PAC recommended a revision to the definition of "direct and observe" to provide more operational flexibility while still ensuring adequate oversight. This remains an area operators should monitor carefully as the final rule develops.

Have questions about covered tasks and your OQ program? Contact EWN for expert guidance.