What is OQ?
The Operator Qualification Rule is part of 49CFR Part 192 (subpart N) and 49CFR Part 195 (subpart G) under the Department of Transportation, Office of Pipeline Safety. This rule requires pipeline operators to develop and maintain a written qualification program for individuals performing covered tasks on pipeline facilities.

What are the key dates associated with OQ?
• October 26, 1999 ­ OQ rule went into effect

• April 27, 2001 ­ Operators must have a written qualification program

• October 28, 2002 ­ Operators must complete the qualification of individuals performing covered tasks

What is H&M required to do under OQ?
The rule applies only to operators. H&M is not required to do anything under the rule. H&M is required to meet the requirements our customers specify in their contracts with us. These contractual requirements will be 1) provide "qualified" workers, and 2) keep records of each worker and his/her qualification to perform covered tasks.

What is a covered task?
A covered task is an activity, identified by the operator (our customer) that:
• Is performed on a pipeline facility

• Is an operations or maintenance task

• Is performed as a requirement of this part

• Affects the operation or integrity of the pipeline

New construction work does not fall under this rule.

What is H&M now doing to get ready for OQ?
• Henkels & McCoy joined the Energy Training Network Qualified For One Qualified For All consortium in March of 1999. This consortium is made up of pipeline operators and contractors who have a common interest in maximizing the benefits of OQ while keeping costs as low as possible. The consortium members agree to accept a common Covered Task List and to accept the qualifications of each other's workers, through a common data base, to perform covered tasks.

• H&M personnel participated in the ETN Covered Task identification process for the Q41 consortium.

• We developed an OQ Plan as if we were the operator. This process helped us understand the OQ requirements and the work that our customers were having to go through in this matter. It also gave us a plan to offer to future customers who may be looking for a guide in their own OQ process.

• We have instructed our IT Department to review the Q41 records program, OQPlus, and determine how to integrate it with our own personnel records as well as other possible record systems our customers may develop.

• Our Sales and Operations people take every opportunity available to discuss OQ with customers and prospective customers. This exchange of ideas and developments will keep H&M at the forefront of OQ compliance.

• We are developing training programs for our people to provide Covered Task training for workers not trained by our customers.

How do these steps help our customer?
Our goal is, and always has been, to be prepared to provide quality service to our customers. In the past, this has meant maintaining a trained work force equipped with the necessary tools and equipment to meet the needs of our customers. Today, this also means being knowledgeable of, and prepared to satisfy, the requirements of the Operator Qualification rule.

What more can/should H&M do to meet our customer's expectations of contractor OQ compliance?
Take every opportunity to discuss this issue with customers and prospective customers. Share the answers received with our pipeline operations, sales, and headquarters people to help H&M become the contractor industry expert on OQ.

What language do/will our contracts have in regards to OQ for contractors?
Our customers do not seem to be sure of this question at this time. Read all contracts, statement of work, and bid requests very carefully for OQ requirements. Be sure you understand exactly what is required of H&M in the performance of the contract. Training (what kind, who pays) and qualification of workers

How do I get more information on OQ?
The entire OQ Rule can be found on the web at http://ops.dot.gov/regulate.htm under the title "Pipeline Safety: Qualification of Pipeline Personnel, 49 CFR Parts 192 and 195 Final rule".