5 Questions You Should Be Asking of Your OQ Plan

The Who? What? When? Where? Why? Behind OQ Plans

The answers to the 5 W(s) constitute a formula for getting the complete story on a subject and are a popular method for investigators and journalists. Many believe that a report (or plan) can only be considered complete if it answers all 5 of these questions. Interestingly, none of these questions can be answered with a simple “yes” or “no” in order to fulfill the requirements of the formula but must contain the details. Is your OQ plan telling the complete story? Check your plan against the 5 W(s) to find out.

Who?

• Operators who perform covered operations or maintenance activities (covered tasks) on a pipeline system.
• Individuals who perform covered tasks on a pipeline system.
• The person or persons responsible for ensuring the requirements of the plan are carried out.

What?

• Operators must identify covered tasks being performed by company employees or contractor employees on the company pipeline.
• Operators must establish a plan detailing how individuals performing covered tasks are to be evaluated and confirm these individuals are prepared to react under abnormal operating conditions (AOCs)
• This plan should include requirements for both Operator and Contractor employees.
• Operators must also determine how any changes to the plan are to be communicated to the affected individuals.

When?

• Operators must establish a distinct plan for evaluating individuals under the following conditions:

A. Newly hired individuals
B. Individuals who are transferring jobs
C. Individuals who may have contributed to an accident or incident
D. Individuals who have failed evaluation or re-evaluation
E. There is reason to believe an individual may no longer be qualified

• Re-evaluation intervals must be established for each task so that an individual demonstrates qualification on a regular basis.
• An Operator must determine when a not qualified individual may perform a task when directed and supervised by a qualified individual. (Span of Control)

Where?

• Records of training and qualification must be kept and made available to state and federal pipeline safety inspectors. The plan must state where these records are to be kept.

Why?

• To protect people and the environment by ensuring the safe transportation of natural gas and other hazardous materials by pipeline.
• To comply with federal regulations 49 CFR 192 subpart N and 49 CFR 195 subpart G.

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