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Operator Qualification

Summary of Rule
As of October 26, 1999, in accordance with 49 CFR 192 and 195, pipeline operators are required to develop and maintain a written qualification program for individuals performing covered tasks on pipeline facilities. The intent of this qualification rule is to ensure a qualified work force and to reduce the probability and consequence of incidents caused by human error. This final rule creates new subparts in the gas and hazardous liquid pipeline safety regulations. It establishes qualification requirements for individuals performing covered tasks, and amends certain training requirements in the hazardous liquid regulations.

Effective When?
The federal regulation became effective October 26, 1999. All operators were required to have a written plan by April 27, 2001. All individuals performing a covered task were required to be Operator Qualified by October 28, 2002, or be directed and observed by an individual of qualified status.

Applies to Who?
The federal regulation applies to every liquid and gas operator with jurisdictional facilities. Jurisdiction extends to the outlet swivel of a meter. Operators include small distribution systems and master meter systems, with one or more individuals performing covered tasks.

Becoming Compliant

Written Plan
As of April 27, 2001, all operators were to have a written OQ Plan in effect. The formula for writing a basic OQ plan is as follows:

1. Review Operations and Maintenance Manual
The OQ Plan can and should be derived directly from an operator's O & M Manual and should include the following:
- Identify All Covered Tasks
- Identify All Personnel Performing Covered Tasks
- Identify All Contractors Performing Covered Tasks
- Specify Qualification Process for Company Personnel
- Specify Operator Qualification Process for Contractors
2. Identify All Covered Tasks
All covered tasks should be identified and written in the OQ Plan. In order for any task to be considered a Covered Task, it must meet all four of the following criteria:
1. Is performed on a pipeline facility;
2. Is an operations and maintenance task;
3. Is performed as a requirement of 49 CFR 192 and 195;
4. Affects the operation and integrity of the pipeline.
3. Identify All Personnel Performing Covered Tasks
Any and all company personnel performing a covered task needs to be identified in the OQ Plan. Updated records should be kept for any employee performing a covered task, including a date of evaluation or reevaluation for qualification of that employee.

4. Identify All Contractors Performing Covered Tasks
Any and all contractors performing a covered task on an operator's system needs to be identified in the OQ Plan. Updated records should be kept for any contractor performing a covered task on an operator's system, including a date of evaluation or reevaluation for qualification of that contractor.

5. Specify Qualification Process for Company Personnel
There are several means of qualifying any and all individuals performing a covered task. Some methods of qualification are training, oral testing, written testing, performance evaluations, on the job training, and simulations. Work history may no longer be used as a sole determinant of qualification as of October 28, 2002. Whatever means of qualification a company chooses to use must be specifically detailed in that company's OQ Plan as well as defining a basis for reevaluation.

6. Specify Operator Qualification Process for Contractors
It is the operator's responsibility to determine whether or not a contractor is operator qualified and whether or not that qualification meets the standards of that operator. For example, if a contractor has a different reevaluation period for a certain covered task from the operator's reevaluation period for that covered task, then the operator must be able to justify the basis for allowing that contractor's reevaluation period as adequate for qualification. Contractors may be qualified in the same manner that operators are qualified in the above paragraph.

How Can B.enviroSAFE, Inc. Help?

Accredited Training Sponsor
B.enviroSAFE, Inc. is an Accredited Training Sponsor recognized by the National Center for Construction Education and Research (NCCER). Our team has put together a five week training course that includes written testing, covering Gas Pipeline Operations, Liquid Pipeline Field Operations, Liquid Pipeline Control Center Operations, Pipeline Corrosion Control, Pipeline Electrical and Instrumentation, Pipeline Maintenance, and Pipeline Mechanical. Each pipeline category is broken down further into Modules. Please see the general training schedule for each pipeline category, modules, and included covered tasks. Each training session is filled on a first come first serve basis. Seating is limited. Please contact Randy Bartley for more information.

Accredited Assessment Center
B.enviroSAFE, Inc. is also an Accredited Assessment Center, again recognized by the NCCER. As such, B.enviroSAFE, Inc. is part of the National Craft Assessment and Certification Program (NCACP), and is able to assess the journey-level knowledge and skills of craftworkers, provide task-specific feedback and knowledge for upgrade training, and certify a participant's successful performance on knowledge or written and skill components of the assessment process. This is an alternative to our training program, and also allows us to administer performance evaluations to assess the skill level of individuals performing covered tasks on pipeline facilities. In recognition of special training needs, B.enviroSAFE, Inc. offers a Distance Learning or Self-Study Program.