Operator Qualification (OQ) Program
In 1999 the DOT amended gas and liquid pipeline regulations to include Operator Qualifications (OQ) rules. The OQ Rule became effective in October 2002. It requires operators of pipelines to use only qualified personnel to perform key operating and maintenance work designated as "covered tasks," regardless of whether the personnel are employed directly by the operator, or by a contractor or subcontractor. Qualified personnel must also be able to recognize and react to "abnormal operating conditions."
Under the DOT Qualification Rule, covered tasks are those work activities that meet the following four criteria:
- It is performed on a pipeline facility, and
- Is an operations or maintenance task, and
- Is required by Parts 192 and 195, and
- Affects the operation or integrity of the pipeline
The OQ rules are performance-based requirements, and the pipeline operator chooses how best to comply with the Rule. The Rule requires that pipeline operators have a written plan that identifies their covered tasks, and the methods that will be used to qualify personnel for the covered tasks.
Some crafts have qualification requirements covered in other sections of the DOT regulations, within project construction specifications or procedures or by other company requirements. Qualification may be required under technical standards and practices of other industry organizations (e.g. API 1104, AWS, API 653, ASNT, NACE, etc.). Inspectors should be aware that any previously established qualification requirements will likely remain unchanged. In some cases, previously established qualificationss do not meet all the regulatory requirements of the OQ Rule; qualification under both the OQ process and the previously established standard will be required. For example, an NDT inspector certified by ASNT will also need to complete qualifications for OQ covered tasks they perform; recognition of abnormal operating conditions is not part of ASNT certification. It is possible that pipeline companies will require more frequent or alternate re-qualification intervals to achieve compliance under the OQ Rule.
Although new construction work is not included within the rule's scope of operating and maintenance tasks, some pipeline companies have chosen to require that construction inspectors qualifications be evaluated in order to perform inspections.
As a contractor providing services to the pipeline industry, how does GIFS support pipeline companies in complying with the Rule?
GIFS ensures that its employees are qualified to perform the covered tasks that they are requested to perform by client pipeline companies.
GIFS subscribes to and evaluates personnel through Veriforce and NCCER / ISNetworld. GIFS is an Accredited Training Sponsor of the NCCER and has a Master Trainer on staff. When new or additional covered tasks or qualifications are required, GIFS arranges for additional OQ evaluations. Workers may become qualified to perform covered tasks by passing written or oral examinations or performance verification (PV) qualification tests or by other methods. Knowledge requirements may be evaluated by either a written or oral test. Skills may be evaluated through a skill demonstration, or job performance measure. All evaluations and testing will be performed in accordance with the clients written plan.
GIFS also works with Veriforce and ISNetworld in setting up and maintaining complete and accurate information on employee and company statistics, our employee health and safety program, OSHA logs, Experience Modification Rate (EMR) letters and current insurance certificates on the ISNetworld and Veriforce OQ web sites.
GIFS is a member of the Pipeline Contractors Roundtable Group (PCRG). PCRG is a proactive voice within the pipeline industry to represent the interests and concerns of pipeline and pipeline related contractors - to provide a safe and qualified work force and to assist in the standardization of the DOT Operator Qualifications.
List of applicable Occupational Health and Safety Legislation, and Federal regulations and codes:
A - Department of Transportation 49CFR 190-199
B - OSHA 29 CFR 1926 - Construction Industry Regulations
C - OSHA 29 CFR 1910 - General Industry Regulations
OQ Links:
Department of Transportation, office of Pipeline Safety http://ops.dot.gov/
Veriforce http://www.veriforce.com
ISNetworld http://www.isnetworld.com
Pipeline Contractors Roundtable Group (PCRG) http://pipelinecrg.org
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