PHMSA Protocols 8 & 9

Continuing EWN's series on PHMSA's OQ Inspection Protocols and Form 14, this post covers Protocols 8 and 9 — both focused on the evaluation methods used to qualify individuals for covered tasks.

Protocol 8: Evaluation Methods

Under 49 CFR 192.805(b), 192.803, and 192.809(d)(e), Protocol 8 requires operators to have documented evaluation methods for each covered task. The evaluation methods must be appropriate to the task — whether written examination, performance demonstration, oral evaluation, or a combination — and must be documented in the OQ plan. Operators must be able to demonstrate to PHMSA inspectors that the evaluation methods actually assess the individual's ability to perform the task.

Protocol 9: Evaluation Methods Records

Protocol 9 requires that the records of evaluation methods used for each individual must match what is documented in the OQ Plan. In other words, if your OQ plan says a task is evaluated by performance demonstration, your records must reflect that performance demonstrations were actually conducted. Consistency between plan documentation and actual practice is what PHMSA inspectors are looking for.

Future installments of this series will continue coverage of the remaining PHMSA OQ Inspection Protocols. For more information, visit the PHMSA website or contact EWN.