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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.

A new rule recently released from PHMSA expands safety and reporting requirements for operators of gas gathering pipelines, including 425,000 miles of lines that were previously unregulated.

Companies rely heavily on third-party contractors for hazardous work, which presents a variety of contractor management challenges, including preventing worker injuries, protecting the company’s reputation, ensuring regulatory compliance, and mitigating potential financial risk if an incident does occur.

In Part 2, we’ll review a short overview of the “Model” Plan for OQ that’s been proposed by the NYSDPS and offering some ideas for how technology and other aspects of a third-party OQ vendor’s solution can help support the types of OQ program improvements that would be required by the NYSDPS’s proposed changes.