The incorrect operation, including maintenance and testing activities, of hazardous liquid and gas pipeline systems by operator or contractor personnel (sometimes referred to as “human error”, “operating error”, or “incorrect operation”) can result in a pipeline failure. Such failures are often accompanied by consequential releases of hazardous liquid or natural gas and the potential for fatalities, injuries, environmental damage, and property damage.
As a result of pipeline incidents caused by incorrect operation, the National Transportation Safety Board (NTSB) made recommendations for the formal qualification of personnel performing certain safety-related tasks on pipelines. The NTSB recommendations were addressed in the promulgation of Federal pipeline safety regulations that set forth the minimum requirements for the qualification of individuals performing covered tasks on a pipeline facility.
What is required for Operator Qualification (or OQ) Programs?
The OQ regulations are set forth in the Code of Federal Regulations, 49 CFR Part 192 Subpart N, for gas pipelines, and 49 CFR Part 195 Subpart G, for hazardous liquid pipelines.
Each pipeline operator that is subject to the Federal pipeline safety regulations under 49 CFR Part 192 or Part 195 must have and follow a written OQ program. Each program must have provisions to:
- Identify covered tasks;
- Ensure through evaluation that individuals performing covered tasks are qualified;
- Allow individuals that are not qualified to perform a covered task if directed and observed by an individual that is qualified;
- Evaluate an individual if the operator has reason to believe that the individual's performance of a covered task contributed to an incident as defined in 49 CFR Part 191;
- Evaluate an individual if the operator has reason to believe that the individual is no longer qualified to perform a covered task;
- Communicate changes that affect covered tasks to individuals performing those covered tasks; and,
- Identify those covered tasks and the intervals at which evaluation of the individual's qualifications is needed.
An operator must also notify the PHMSA Administrator or a state agency participating under 49 U.S.C. Chapter 601, if the operator significantly modifies the program after the Administrator or state agency has verified that the program complies with the regulations.
Operators must provide appropriate training and evaluation to ensure that individuals performing covered tasks have the necessary knowledge and skills to perform the tasks in a manner that ensures the safe operation of pipeline facilities, and the ability to recognize and react to abnormal operating conditions.
What OQ records are required?
Operators must maintain records of their OQ programs to demonstrate compliance with the regulations. The records must include identification of qualified individuals, identification of the covered tasks each individual is qualified to perform, dates of each individual’s current qualification, and the qualification methods used. Neither an individual’s work performance history nor observation of the individual’s on-the-job performance may be used as the sole method of qualification evaluation by the operator.
Records supporting an individual's current qualification must be maintained while the individual is performing the covered task. Records of prior qualification and records of individuals no longer performing covered tasks must be retained by the operator for a period of five years.
How is an operator’s compliance to the regulations ensured?
Jurisdictional operators’ OQ programs are inspected by Federal and state pipeline safety inspectors for compliance with the regulations. Inspectors utilize a detailed set of inspection questions to ensure consistency in performing the inspections. OQ inspections cover the operators’ written OQ programs and their implementation.
In summary, pipeline operators are required to ensure through formal, written OQ programs that all personnel who perform certain safety-related (covered) tasks on a hazardous liquid or gas pipeline have the knowledge, skills, and abilities to correctly perform the tasks, and that qualified individuals can recognize and react properly to abnormal operating conditions.
Safety regulations address what defines a covered task, what each operator’s OQ program must include, and what records are kept.
Operator Qualification: Where can I learn more?
- PHMSA OQ Website
- 49 CFR Part 192 Subpart N (for gas pipelines)
- 49 CFR Part 195 Subpart G (for hazardous liquid pipelines)
- PHMSA Pipeline Incident Trends
- PHMSA Community Liaison Services
- PHMSA OQ Inspection Forms
Date of Revision: 10/09/2015