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Operator Qualification: Evaluating the Evaluator And Reclaiming Your Procedures for An Effective Program

November 5, 2019 @ 8:00 am - 4:30 pm


Operator Qualification (OQ) has been required for all operators since its Final Rule in 1999. According to regulatory data, as the OQ rule has grown and evolved, OQ programs have become inconsistent, lacking operator accountability for all individuals working on their system. Additionally, many pipeline operators scaled back and/or eliminated their own training facilities and training programs and have replaced them with regionalized OQ “qualification.”

As a result, in many cases, training programs offered today develop a fraction of the skills they offered immediately before implementation of the 1999 OQ rule and rarely focus on performance of covered tasks using specific operator procedures and equipment.

In addition to these gaps, there are even more federal requirements ahead. Through proposed NPRM (Miscellaneous Rule – 7/5/2015) and Combined Technical Committee discussions, possible new rules would require the following:
• Program Effectiveness Review
• Inclusion of New Construction
• Additional Record Requirements
• Training Requirements
• Inclusion of Type A (Class 2) and Type B Gathering (Onshore)
• Inclusion of Regulated Rural Hazardous Liquid Gathering

PHMSA has also addressed developing criteria for evaluators, defined “qualified”, “emergency response tasks”, “knowledge, skills and abilities” and “direct and observe”.
These new and amended regulations would apply to interstate and intrastate natural gas and hazardous liquid pipeline facilities.

Discussion for this course is specifically around:
49 CFR 192.800’s & 195.500’s
The components of a successful OQ Program and the factors that affect it

This goal of this training is to provide tangible understanding of the requirements and the impact of each to an existing or new OQ program.

This Training Is Useful For
O&G executives and managers
OQ program managers (old and new)
Pipeline project managers
Compliance managers
Energy attorneys
Regulators and regulatory affairs personnel
Energy consultants


8:00-8:30 a.m. Registration and Continental Breakfast

8:30-9:30 a.m. OQ Background & Overview
• History
• Case Study
• Advisory bulletins
• Applicability and exclusions
• PHMSA Reauthorization (Bill Discussion)
• Rulemaking

9:30-10:00 a.m. Roles & Responsibilities
• Designated Individuals

10:00-10:15 a.m. Morning Break

10:15-10:45 a.m. Required Procedures & Maintenance
• OQ written plan
• Overall OQ program

10:45-11:15 a.m. Evaluators Criteria
• Requires defining criteria for evaluators
• Requires established training for evaluators

11:15 a.m. – 12:00 p.m. Covered Tasks and Training
• Amended four-part test
• Development of new covered tasks
• New construction
• Method of evaluation for KSA’s
• Training required for each covered task

12:00 – 1:00 p.m. Group Lunch

1:00-2:00 p.m. Evaluations
• Determining Evaluation Method(s)
• Evaluation Criteria
• Administration of the Evaluations

2:00-3:00 p.m. Program Effectiveness
• Explicit requirement review
• Development of additional PE measure(s)
• PE requires review of evaluators
• Performance of the review
• Follow up to review

3:15-3:45 p.m. Recordkeeping
• Current requirements
• Amended requirements
• Understanding the integration of the records

3:45-4:15 p.m. Management of Change
• Policies and procedures
• Implementation
• Impact of changes

4:15-4:30 p.m. Remaining Questions

4:30 p.m. Day Ends

Our Instructor

Warren Miller, Owner, Warren Miller Enterprises, LLC
Warren is the founder of Warren Miller Enterprises, LLC, a consulting firm focusing on regulatory compliance in the pipeline industry. He has extensive experience in all aspects of the natural gas and hazardous liquid industry from the regulatory compliance side.

Warren started Warren Miller Enterprises, LLC in April 2016, providing regulatory assistance and consultation services to pipeline operators, contractors and companies in areas of Operator Qualification (OQ), Operations & Maintenance, Drug and Alcohol, Control Room Management and Integrity Management. This includes program development, program assessment/audit, pre-audit inspections, audit support, post-audit assistance/development, accident/incident investigation and regulatory training in both the natural gas and hazardous liquid industries. He is a member of the OQ Integrity Coalition currently developing an improved program for distribution gas operators and contractors. He maintains status as a current member of the ASME B31Q Standard Committee.

After retiring in 2014, Warren worked as a Senior Regulatory Compliance Specialist, where he provided program assessments, procedure development, covered task development, regulatory training and regulatory assistance for operators and contractors.

Warren served with the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) for more than 22 years. He joined the PHMSA Office of Pipeline Safety in Denver in September 1991, as a Petroleum Engineer. His duties included inspection of interstate and intrastate operations of hazardous liquid and natural gas pipelines from construction through operations, development of compliance actions addressing deficiencies found during inspection, support during specific hearings, and accident investigation. He also performed duties as a State Liaison where he evaluated the pipeline safety programs of the twelve states in the Central Region for seven years.

He later co-developed the inspection protocols, forms, training and guidance for the OQ regulations and represented PHMSA on the ASME B31Q Qualification of Pipeline Personnel Technical Committee until he retired in 2014. Warren also chaired a federal and state committee for ensuring a consistent inspection process and assisted training federal and state inspectors on OQ. In 2010, he facilitated the PHMSA OQ Federal/State Committee, whose charter was to address issues that arose in the field as inspectors inspected OQ programs and to investigate quality management benefits. Prior to his retirement, he assisted in drafting the OQ NPRM and performed an analysis and study on quality management and where it could be used in the pipeline industry.
He maintains status as a current member of the ASME B31Q Standard Committee.

Prior to 1991, Warren consulted in the oil and gas industry for numerous operators that did not have staff to drill and complete oil and natural gas wells. He worked from Texas to Wyoming while assisting operators with regulatory requirements, from staking the location of the wells, drilling, completion and connecting production to gathering lines.


November 5, 2019
8:00 am - 4:30 pm


Denise Raymond


Crestwood Midstream Partners
811 Main St suite 3400
Houston, TX 77002 United States
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