Clarifying the New PHMSA Operator Qualification (OQ) FAQs

May 16, 2022
Tom Meek

The PHMSA OQ Rule, designed to govern the day-to-day performance of an oil and gas worker, went into effect in 2002. New OQ FAQs were released on January 28, 2022 to provide guidance around complying with the legacy rule. While the FAQs don’t carry the weight of the existing regulations, they were released for a reason — to aid businesses in their quest for compliance.

FAQ #7 and #8:
Key Questions

While the complete FAQs include dozens of questions and answers, sections 7 and 8 are the most relevant and impactful for oil and gas organizations today.

FAQ #7

How should training be incorporated in an operator’s program?
(§§ 192.805(h), 192.807, 195.505(h), 195.507) Suggests that training be completed at multiple times during the operator life cycle, including when:

  • Onboarding new employees to your organization, whether they have experience or not
  • Introducing use of a new piece of equipment
  • Reviewing specifics related to an organization’s unique pipeline or changes in procedures for performing specific tasks
  • Reviewing information annually, or another regular training opportunity
  • Retraining after a failed qualification

FAQ #8

What is the role of computer-based or web-based training in complying with the OQ Rule? (§§ 192.805(h), 192.807(a)(4), 195.505(h), 195.507(a)(4))

Operators may choose the type and method of training; computer-based and web-based training represent two permissible choices available to operators. 

Training must address an operator’s pipeline system characteristics, equipment, and procedures. See 64 FR at 46863. Training programs and methods may be reviewed by regulators during inspections.

Best Practices
to Achieve OQ Compliance

While the FAQs aren’t the rule, they do offer additional information and can shape the way an inspector will examine your organization. When it comes to OQ Rule compliance, being proactive is key. Use the new FAQs as a guide to help you mitigate risk and reduce risk to the public and the environment.

To maintain compliance and work in training from the FAQs, focus on these 5 best practices:

  1. Offer training. Whether this means preparing for workplace safety or a specific job, training is the key to risk management. 
  2. Review policies and procedures. Review your existing policies and procedures to ensure they are complete, and then determine the best way to communicate them to your workers. 
  3. Maintain records. Documentation of employee and contractor training should include all the basic information: name, task, qualification and method of how they qualified, and be retained for 5 years for each worker.
  4. Ensure qualification.  Everyone who comes on site to perform covered work must be qualified prior to performing covered task(s) or work under the control of a qualified employee. Verify individual qualifications before starting any project.  
  5. Re-evaluate training needs. The FAQs recommend updating and reviewing the operator’s procedures in particular, in the event of any significant change. 

About the Author

Tom Meek
VP of Regulatory Compliance, Veriforce

Find out more about the new PHMSA Expanded Gas Gathering Pipelines Rule and Operator Qualification (OQ) FAQs.