Span of Control - Still a Gray Area, But Getting Clearer

Span of Control - Still a Gray Area, But Getting Clearer

This one has come up a few times recently, so it’s worth spelling out clearly. Span of control refers to the practice of allowing an unqualified worker to perform a covered task while being directed and observed by a qualified person. Specifically, ‘span of control’ is the ratio of how many unqualified workers can be effectively ‘directed and observed’ by a qualified worker. The term is not formally defined in the PHMSA regulations, but is in industry standards (ASME B31Q, etc.).

The Core Question Operators Keep Asking

How many unqualified workers can one qualified person direct and observe at the same time?

From a regulator’s perspective, anything beyond a one-to-one ratio is very difficult to justify. State approaches vary, but the direction of travel is consistent. PHMSA’s FAQs on the issue make it clear that:

• The qualified individual must be close enough to direct and observe the unqualified individual so that they can recognize and react to abnormal operating conditions and take immediate corrective action.
• The operator must consider all relevant factors, including physical space limitations, as well as environmental conditions such as noise, visual obstructions, and weather.
  

Some states have gone further and added Span of Control limitations in their state regulations. For example:

• Connecticut limits span of control to exactly one-to-one - one qualified, one unqualified, maximum.
• New York requires that whatever span of control an operator uses must be justified and documented by the operator.

What Regulators Are Really Looking For

The central test is simple: could the qualified person physically step in and take over if something went sideways? Proximity matters.

• If two workers are in very close proximity, a two-to-one ratio might be defensible.
• If they’re at opposite ends of a block, it’s not.
• If there’s only room in the trench for one person, span of control is practically impossible to justify - regardless of policy.

The Documentation Burden - A Nationwide Issue, Not Just the Northeast

The documentation burden is what’s driving some operators in the Northeast to reconsider using span of control for OJT altogether. This is not a regional concern - it applies to any operator using span of control as part of their OJT process, anywhere in the country.

The moment span of control is part of how an operator qualifies workers through OJT, documentation becomes an operational requirement, not a best practice. Operators need to be able to demonstrate, for any given covered task, who was directing and observing the unqualified worker, when, and under what conditions. Without that record, the qualification is difficult to defend during an audit or inspection.

Key documentation considerations for any operator using span of control in OJT:

• Who was the qualified person directing and observing?
• What covered task(s) was being performed?
• When did it occur?
• Where did it occur?
• How was proximity maintained to allow for immediate intervention if needed?

The regulator’s standard is blunt: If you documented it, you did it. If you didn’t document it, you didn’t do it. That standard applies whether an operator is in Connecticut, Texas, or anywhere in between.

How EWN Can Help

EWN’s platform can help operators document who was directing and observing an unqualified worker for the completion of any given covered task - creating a clear, auditable record that ties the qualified person to the specific work performed. That’s a significant value-add as documentation expectations continue to tighten across the industry, not just in the Northeast. Without it, operators may struggle to demonstrate that a covered task was properly supervised or that the worker that performed it was legitimately qualified through OJT.

Bottom Line

Span of control remains a viable tool for OJT – especially for OJT - but only when it’s used with the rigor regulators expect. That means defensible proximity, a justifiable ratio, and documentation that proves the qualified person was actually there, actually observing, and actually capable of stepping in. If your program relies on span of control and your documentation doesn’t reflect that level of detail, it’s worth a hard look - regardless of where you operate.