One of the common issues I have seen with operator qualification programs for both gas operators and hazardous liquid operators is not including covered tasks done by third party contractors in the operator’s OQ written program and covered task list. Because the contractor is performing a task on the operator’s pipeline that meets the four part test is must be included in the operator’s covered task list. Pipeline safety code under Parts 192 and 195 holds the operator responsible for activities on their pipeline not third party contractors.
If you have not reviewed your covered task list in a while for inclusion of tasks done by third party contractors, I recommend doing so. If you would like help, I would be happy to do a thorough review for you.
This month’s special: 25 % off the standard consulting rate for any operator qualification work.