Veriforce® Operator Qualification (OQ) basics for contractors

Federal pipeline safety rules require that anyone doing a "covered task" on a pipeline be qualified, or be directed and observed by someone who is ^[1][3][5][6]. The pipeline operator owns that program and sets the covered tasks and how often workers must be re-evaluated ^[3][6]. Many operators manage this through Veriforce®, where contractors keep qualification records and operators check them ^[9][11]. If your worker is not qualified under that operator's program, the operator has to keep them off the covered task unless a qualified person directs and observes them ^[3][6][8].

What is operator qualification under federal rules?

Operator qualification is set out in 49 CFR Part 192, Subpart N for gas pipelines and 49 CFR Part 195, Subpart G for hazardous liquid pipelines ^[1][5]. Both rules state: "Each operator shall have and follow a written qualification program." ^[3][6] PHMSA says the operator is responsible for qualification "regardless of whether these individuals are operator employees, contractor employees, or other personnel." ^[8] The operator must also "verify and document that the contractor's or other operator personnel's qualifications" meet its written program ^[8].

What counts as a "covered task"?

Under 49 CFR 192.801(b) and 195.501(b), "a covered task is an activity, identified by the operator, that:" ^[1][5]

1. "Is performed on a pipeline facility;" ^[1][5]
2. "Is an operations or maintenance task;" ^[1][5]
3. "Is performed as a requirement of this part; and" ^[1][5]
4. "Affects the operation or integrity of the pipeline." ^[1][5]

The words "identified by the operator" matter. Each operator builds its own covered task list ^[1][5]. PHMSA says an off-the-shelf program "does not excuse the operator from its regulatory obligation to identify a covered task." ^[8]

What does "qualified" mean?

The rule defines "Qualified" as meaning "that an individual has been evaluated and can: (a) Perform assigned covered tasks; and (b) Recognize and react to abnormal operating conditions." ^[2][16]

An "Abnormal operating condition" "means a condition identified by the operator that may indicate a malfunction of a component or deviation from normal operations that may: (a) Indicate a condition exceeding design limits; or (b) Result in a hazard(s) to persons, property, or the environment." ^[2][16]

"Evaluation" "means a process, established and documented by the operator, to determine an individual's ability to perform a covered task by any of the following:" written examination, oral examination, work performance history review, observation during performance on the job, on the job training, or simulations, and "Other forms of assessment." ^[2][16] After December 16, 2004, observation of on-the-job performance may not be the only evaluation method ^[17].

What must the operator's written program include?

Each operator's program must include provisions to ^[3][6]:

• Identify covered tasks ^[3][6].
• Ensure through evaluation that people doing covered tasks are qualified ^[3][6].
• Allow unqualified people to do a covered task only "if directed and observed by an individual that is qualified" ^[3][6].
• Re-evaluate a person if the operator believes their performance contributed to an incident (gas) or accident (liquids), or that they are no longer qualified ^[3][6].
• Communicate changes that affect covered tasks to the people doing them ^[3][6].
• "Identify those covered tasks and the intervals at which evaluation of the individual's qualifications is needed" ^[3][6].
• Provide training, as appropriate, so workers have the knowledge and skills to do the tasks safely ^[3][6].

The regulation does not set one requalification interval for every task ^[3][6]. PHMSA states: "the regulation does not specify the period of time that may elapse between evaluations." ^[8] PHMSA says intervals may be affected by task difficulty or complexity, task importance and related factors ^[8]. Your interval for a given task comes from the operator's written plan ^[3][6].

What records are required?

Qualification records must include identification of the qualified person, the covered tasks they are qualified to perform, the date(s) of current qualification, and the qualification method(s) ^[4][7]. Records supporting current qualification must be kept while the person is doing the covered task ^[4][7]. Records of prior qualification, and of people no longer doing covered tasks, "shall be retained for a period of five years." ^[4][7]

How does Veriforce® support OQ for contractors?

Veriforce® describes its OQ offering as covering compliance documentation, evaluator tools and training content for pipeline operators and contractors ^[9]. Here is how the pieces fit, based on Veriforce® materials.

Training. Veriforce® offers a Common Covered Tasks eLearning library of 165+ courses, plus additional distribution and LNG courses ^[11]. It says courses are available on demand and that course results are automatically tracked ^[12]. Veriforce® says its content is aligned to ASME B31Q and API standards ^[9][11].

Performance evaluations. Veriforce® says evaluations are done in person by authorized evaluators who "Conduct in-person evaluations of DOT covered tasks." ^[9][10] It says the process "measures an individual's knowledge, skills, and abilities through an in-person evaluation." ^[10] Evaluators also check that workers can recognize and respond to abnormal operating conditions ^[10].

Authorized evaluators. To become one, a person applies, submits technical and character references, waits for review, and then completes Evaluator Authorization Training, which ends with a final exam ^[10]. Veriforce® says it performs desktop and field audits of authorized evaluators ^[12].

Records and operator visibility. Veriforce® says it maintains "a full audit trail of all qualifications." ^[12] Operators can track covered task qualifications, identify upcoming expirations and access field verification reports ^[12]. Veriforce® says field verification reports show OQ status, drug and alcohol compliance and worker profiles in one view ^[15]. It also says worker records can be verified using a digital ID ^[11].

Operator task lists. Veriforce® runs a Common Covered Task list used by many operators ^[13]. Each operator still must consider the 4-part test before activating a task, and the interval for a task appears in the operator's specific covered task list ^[13].

What does a contractor need to do to get workers qualified?

1. Get the operator's requirements. Ask which covered tasks your scope includes and which OQ program the operator uses, since the operator identifies covered tasks and verifies contractor qualifications ^[1][8].
2. Complete required training. Some operators require training before evaluation, and the rule calls for training "as appropriate" ^[3][6].
3. Schedule evaluations. Veriforce® says workers can request and schedule evaluations in the field before qualifications expire ^[11].
4. Review operator-specific procedures. Veriforce® has described a process where operator procedures are loaded into its training system for contractors to review and acknowledge ^[14].
5. Check the records. Confirm each worker's record shows the right tasks, dates and methods ^[4][7].
6. Track expirations. Set reminders well ahead of each interval in the operator's plan ^[3][12].

Why does a worker show as not qualified?

These are common causes tied to how the rules and records work:

• Expired qualification. The interval in the operator's plan has passed ^[3][6][12].
• Wrong or missing task. The worker is qualified on a different task than the one the operator listed for the job ^[1][4].
• Re-evaluation triggered. The operator has reason to believe the worker contributed to an incident or accident, or is no longer qualified ^[3][6].
• Failed evaluation. PHMSA says operators should set reevaluation requirements after a failed evaluation ^[8].
• Drug and alcohol status. Veriforce® field verification reports show D&A compliance next to OQ status, so a D&A issue can block the worker from approval for work ^[11][15].
• Operator procedure not acknowledged. Where an operator uses procedure acknowledgment, an open item may show ^[14].

Frequently asked questions

Does my OQ carry over between operators?
It depends on each operator's written plan. PHMSA says the operator must "verify and document" that contractor qualifications meet its own written OQ program ^[8]. A shared task list such as the Veriforce® Common Covered Task list can help, but each operator still activates tasks and sets intervals for its own operations ^[13]. None of the sources reviewed promise automatic transfer.

Is third-party evaluation required?
No. PHMSA answered "No" when asked if third-party evaluation is mandatory ^[8]. The operator decides how evaluations are done within the rule ^[2][3].

How long must qualification records be kept?
While the person performs the covered task, and five years for prior qualifications or for people who no longer perform covered tasks ^[4][7].

Do I need a consultant for OQ?
No. A contractor can manage OQ directly with the operator and Veriforce®. A consultant is optional and can help if you are juggling multiple operators, task lists and expiration dates.

Not sure where your crew's qualifications stand? Request a free compliance review through our quote form.