Industry Evolution: New OQ Task Requirements

As PHMSA's OQ NPRM continues to evolve, one of the most foundational questions operators are asking is: what tasks will be considered "covered tasks" under the new rule? Understanding this is critical to building a compliant OQ program.

Definition of a Covered Task

Currently, PHMSA uses a 4-part test to determine if a task is a "covered task" subject to OQ requirements. PHMSA's NPRM proposed simplifying this to a 2-part test . However, after review by the GPAC and LPAC committees on June 1, 2016, both committees recommended retaining a modified version of the 4-part test. This reflects the industry's view that the 4-part test, while more complex, provides the appropriate level of rigor for identifying covered tasks.

New OQ Requirements for Gathering Lines

The NPRM also proposes to extend OQ requirements to gathering lines. Under new provisions in 49 CFR 192.9 and 195.11, operators of gathering lines would be subject to OQ requirements for the first time, expanding the scope of covered tasks across the industry.

OQ Compliance Requirements

Operators must maintain a written OQ plan identifying all covered tasks, the qualification methods for each, and reevaluation intervals. The written plan is the backbone of any compliant OQ program and must be kept current as tasks and regulations evolve.

Span-of-Control

The proposed rule included a 1:1 span-of-control ratio for on-the-job training scenarios. The PAC revised the definition of "direct and observe" to provide more operational flexibility while maintaining the intent of adequate oversight for trainees performing covered tasks.

Have questions about covered task identification for your program? Contact EWN — our compliance experts are here to help.