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What is Operator Qualification? What is The (DOT) OQ Rule? How are Contractors affected by the OQ Rule? What is a Covered Task? How long should I keep these records? / How are records kept? What is Operator Qualification? The requirements of the Department of Transportation Operator Qualification Rule (49 CFR Parts 195 and 192, hereinafter referred to as "the OQ Rule") will place a significant compliance burden on operators and contractors. The following paragraphs explain how the Operator Qualification Solutions Group (OQSG) will benefit both operators and contractors by providing information, recommendations and solutions that will ease the burden of compliance with the OQ Rule. Due in large part to an increasing number of accidents involving operations on natural gas and liquid petroleum pipelines, the U.S. Department of Transportation established guidelines that require pipeline operators to develop a written program for qualifying personnel that perform certain types of work on DOT pipelines. Operators were required to have a completed written qualification plan in place by April 27, 2001. The objective of requiring pipeline operators to have a written qualification program is to make the operators responsible for improving the quality of the pipeline workforce, including both company employees and contract personnel. Back to Top
What is The (DOT) OQ Rule? Each operator of a DOT Pipeline must have a written plan that will provide the guidelines and procedures each company will use to evaluate and qualify company personnel and contractors that perform covered tasks. Basically, the plan must 1. Identify Covered Tasks
2. Provide acceptable methods for Personnel Qualification
3. Provide Record Keeping procedures for Qualified Personnel The following paragraphs will go into more detail. For more information regarding the OQ Rule and how it will affect your company, please refer to PUBL 1161: Guidance Document for the Qualification of Liquid Pipeline Personnel, provided by The American Petroleum Institute. Back to Top
How are Contractors affected by the OQ Rule? The responsibility of 1) identifying covered tasks and 2) ensuring personnel are qualified to perform them, is placed solely in the hands of the pipeline operators. Operators will be required to make sure that both employees and contract personnel are qualified according to the operator's written plan. Two key issues arise from these requirements: 1) Covered tasks vary among operators - There are some operators that have identified over 200 covered tasks and some that have identified as few as 20. The differences in covered tasks between operators will increase the compliance burden on contractors. 2) Personnel evaluation methods vary among operators - The OQ Rule requires an operator to list the appropriate evaluation methods for qualifying personnel. Personnel must be evaluated using the methods approved under the operator's written plan. Most operators will accept different methods for evaluation, meaning a contractor may have to qualify an individual using more than one method in order to work for multiple operators. The lack of an industry-approved evaluation solution will greatly increase operator and contractor burden. A potential nightmare for contractors is trying to maintain a "qualified workforce" that is able to perform activities for multiple operators. In order to fulfill this requirement, contractors have had to evaluate personnel using multiple methods. If operators differ in their identification of covered tasks and their acceptable personnel evaluation methods, contractors have been required to go to great expense to comply with each operator's requirements. Back to Top
What is a Covered Task? The OQ Rule does not define specific covered tasks that personnel must be qualified to perform. Each operator's written plan must identify which tasks are considered "covered tasks." The procedure for determining a covered task is based on 4 questions. The answer to each question must be "yes" in order for a task to be considered a covered task. The questions are as follows: 1) Is the Activity Performed on a Pipeline Facility?
2) Is the Activity an Operations or Maintenance Task?
3) Is the Activity Required by 49 CFR Parts 195 or 192?
4) Will the Activity Affect the Operation or Integrity of the Pipeline? If any of these questions can be answered with "No," then the activity is not a covered task and does not fall under the OQ Rule. Pursuant to the OQ Rule, personnel performing covered tasks on DOT Pipelines must be qualified initially by October 28, 2002 or must be under the direct supervision of a qualified person while performing a covered task. It is important to keep in mind, however, that due to the legal liability of non-qualified personnel performing covered tasks, most companies will allow qualified personnel to perform covered tasks. Back to Top
How long should I keep these records? / How are records kept? Operators must keep records for the personnel who perform covered tasks for their company. The OQ Rule states that an operator must maintain records for personnel that perform covered tasks for the operator for a minimum of 5 years from their date of qualification or 5 years from the last date that the individual performed a covered task. Many large operators have intricate record keeping solutions that already track large amounts of information regarding qualifications for a multitude of regulatory actions. Mid-to-small-sized operators and contractors will be the hardest hit by this requirement. Operators will be requesting qualified personnel and will, in all likelihood, be requesting that contractors provide the information in an electronic format for easy import into the operator's record keeping database. It will be beneficial for contractors to be proactive and have quick access to a database of their employees that are able to perform covered tasks. Back to Top
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