Industry Evolution: OQ NPRM Management of Change & Recordkeeping

Two of the most operationally significant proposals in PHMSA's OQ NPRM are the new requirements for Management of Change (MOC) and expanded Recordkeeping. These provisions will require operators to build new processes and systems to remain compliant when the Final Rule takes effect.

Management of Change (MOC)

Under proposed 49 CFR 192.805(b)(7) and 195.505(b)(7), operators would be required to establish a written Management of Change program . The purpose of this requirement is to ensure that whenever significant changes occur — whether to equipment, tasks, procedures, or regulations — the individuals performing affected covered tasks are promptly notified and any necessary reevaluation is triggered.

The MOC program must include records documenting that changes were communicated to covered task performers. This creates a traceable, auditable process that inspectors can verify during OQ audits.

Expanded Recordkeeping

Under proposed 49 CFR 192.809 and 195.509, recordkeeping requirements are significantly expanded. There are two categories of records:

Individual Qualification Records (7 Required Elements)

1. Individual's name
2. Covered task identification
3. Date of qualification
4. Qualification method used
5. Name of evaluator
6. Reevaluation interval
7. Date of next required reevaluation

Program Records (9 Required Elements)

1. Written OQ plan
2. List of covered tasks
3. Qualification methods for each task
4. Reevaluation intervals for each task
5. Records of program effectiveness reviews
6. MOC program documentation
7. Training records
8. Evaluator qualification records
9. Contractor qualification records

Retention Period

Both individual qualification records and program records must be retained for a minimum of 5 years .

Industry Consensus

Both the GPAC and LPAC unanimously accepted the MOC and recordkeeping provisions. The key theme is tracking and traceability — your OQ program must be documented in a way that you can demonstrate compliance at any point in time.

EWN's platform is designed to help operators meet these tracking and traceability requirements. Contact us to learn more.