PHMSA 9 Protocols: Form 14 – 22 Elements (Protocols 10, 11 & 12)

EWN's educational series on PHMSA's OQ Inspection Protocols continues with a look at Protocols 10, 11, and 12 — all focused on Abnormal Operating Conditions (AOCs) and qualification record requirements.

Protocol 10: AOC Training and Evaluation

Under 49 CFR 192.803, Protocol 10 requires that individuals performing covered tasks be able to recognize and react to abnormal operating conditions. Operators must have AOC training and evaluation processes in place for all covered task performers. This is one of the most inspection-sensitive areas of any OQ program.

Protocol 11: AOC Records

Protocol 11 requires documentation that individuals have been evaluated for AOC recognition and response. Under 49 CFR 192.807(a)(b), operators must maintain records that document each individual's AOC evaluation, including what conditions were evaluated and when.

Protocol 12: Qualification Records

Under 49 CFR 192.807, Protocol 12 establishes the full qualification records requirement. Records must be:

• Maintained for a minimum of 5 years
• Include individual identification
• Document which covered task the individual is qualified for
• Record the date of qualification
• Specify the qualification methods used

Proper documentation across Protocols 10, 11, and 12 is essential for demonstrating OQ compliance to PHMSA inspectors. Visit the PHMSA website for the official Form 14, or contact EWN for assistance with your compliance documentation.