The Department of Transportation's Operator Qualification Rule (49 CFR Parts 195 and 192, hereinafter referred to as "the OQ Rule") requires that 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.

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. Although no regulatory program is capable of completely eliminating human error, the objective of this final rule is to reduce the risk of accidents on pipeline facilities attributable to human error.

Requirements of the 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 responsibility of identifying covered tasks and 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.

Covered tasks will vary among operators. Some operators have identified over 200 covered tasks, and some as few as 20. The differences in covered tasks between operators will increase the compliance burden on contractors.

Personnel evaluation methods will 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.

A potential nightmare for contractors will be trying to maintain a "qualified workforce" that is able to perform activities for multiple operators. In order to fulfill this requirement, contractors must have personnel that have been qualified under each operator's plan.

The OQ Rule states that an operator must maintain records for personnel that perform covered tasks for the operator for a minimum of five years from their date of qualification or five years from the last date that the individual performed a covered task.

ADC Recommendations
The ADC has formed a committee to give contractors a better understanding of the operator qualification rule. It is important to note that there is no easy fix - that "one plan does not fit all." There are several companies that offer "standardized" training modules and task lists molded to land-based tasks. None of these companies address specific underwater tasks.

Of the several qualification plans operators have submitted to different diving contractors, this committee selected El Paso Energy's OQ Plan as a model to identify divers tasks. El Paso has listed 132 tasks. This committee identified 28 diver-covered tasks, and 15 partial-covered tasks. Tasks were identified by reviewing El Paso's specific "Task Qualification Standard," and selections were also made by individual committee members and industry experts (project managers, operations managers, etc.).

The committee offers the following guidelines to diving contractors who need to comply with the DOT OQ Plan:

1. Review the Divers Task list and identify those tasks that your personnel perform.
2. Develop a "Written Plan" to qualify personnel (generic samples available).
3. Qualification is the evaluation process, established and documented by the operator, to determine an individual's ability to perform a covered task by any of the following methods (49 CFR 192, Section 192.803 and 49 CFR 195, Section 195.503):
   • Written examination;
   • Oral examination;
   • Work performance history review;
   • Observation during performance, on-the-job training, or simulations;
   • Other forms of assessment.
   • Review El Paso's "OpQual Program for Contractors" for qualifying personnel.
   • "Guidelines for Evaluating Contractor OpQual Programs" includes a checklist that can be used to develop an OpQual program.

Should an ADC member wish further information regarding El Paso's OpQual program, they may contact any of the following based on the name of their company. If the company name starts with:

• A - C: Donald Payne (915-593-0412)
• D - Hod: Bruce Campbell (505-344-9515)
• Hok - Kan: John Chin (248-944-4022)
• Kel - Moo: Amy Livingston (205-327-6926)
• Mur - Rog: Paul Lopez (719-520-4339)
• Rol - S: Greg Hill (928-527-6501)
• T - Z: Lori Jurena (832-676-4193)

For any other questions, call the ADC office (281-893-8388). Each DOT pipeline operator must approve the contractor's plan. The compliance deadline is October 28, 2002.