What is PHMSA Form 14?

PHMSA Form 14 is the inspection form used by PHMSA inspectors to evaluate an operator's Operator Qualification program. It is organized around PHMSA's 9 OQ Inspection Protocols, each of which maps to specific regulatory requirements. Since August 2013, PHMSA has reorganized Form 14 from 9 broad protocols into individual sub-elements, making inspections more granular and documentation requirements more specific.

Element 3: Contractors Adhering to OQ Plan

Under 49 CFR 192.805(b)(f)(c), Element 3 requires that contractors and other entities performing covered tasks on an operator's pipeline system must adhere to the operator's OQ plan. The operator is responsible for ensuring that contractors are qualified under a program that meets the regulatory requirements, and that contractor qualification records are maintained and accessible.

Element 4: Contractor and Other Entity Qualification

Under 49 CFR 192.805(b)(c)(f), Element 4 addresses the specific qualification requirements for contractors. Operators must verify that contractors have a qualification program that meets the requirements of 49 CFR Part 192 Subpart N. This includes verifying that:

1. The contractor has identified covered tasks
2. Covered task performers have been evaluated
3. Qualification records are maintained
4. Reevaluation intervals are established
5. The contractor's program includes AOC requirements

Upcoming posts will continue coverage of Element 6 and Element 7. For more information on PHMSA Form 14 and OQ compliance, contact EWN.