PHMSA OQ Inspection Protocols: Element 1

In our continuing series on PHMSA's OQ Inspection Protocols, we begin with the foundational elements: Element 1 (Operator Qualification Plan and Covered Tasks) and Element 2 (Reevaluation Intervals for Covered Tasks). These two elements form the backbone of any compliant OQ program.

Background: What is a Covered Task?

A "covered task" is any activity associated with operating and maintaining a pipeline facility that: is performed on the pipeline, is an operations or maintenance task, affects the operation or integrity of the pipeline, and is performed by the operator or a person operating the pipeline on the operator's behalf. Properly identifying covered tasks is the first step in any OQ program.

Element 1: Operator Qualification Plan and Covered Tasks

Under 49 CFR 192.805(a) and 192.801(b), operators must have a written OQ program that identifies all covered tasks and establishes the qualification requirements for each. The OQ plan can be developed off-the-shelf, through a consultant, or by the operator directly. What matters is that it comprehensively identifies all covered tasks and is kept current.

Element 2: Reevaluation Intervals for Covered Tasks

Under 49 CFR 192.805(g), the written OQ plan must include reevaluation intervals for each covered task. These intervals define how frequently individuals must be re-qualified for each task they perform. Operators must be able to demonstrate that their reevaluation intervals are appropriate and that all individuals are re-qualified on schedule.

Upcoming posts will continue coverage of additional Form 14 elements. Contact EWN for assistance with your OQ program.