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 DOT QUALIFICATION TRAINING FOR MEASUREMENT AND CONTROL TECHNICIANS
Class 8040

Joey Rockett
Atlas Pipeline
14000 Quail Springs Parkway
Suite 215
Oklahoma City, OK 73134

The Pipeline Hazardous Materials Safety Administration (PHMSA) passed regulation that stated by
October 26, 1999 Pipeline Operators who were subject to 49 CFR 192 and 195, were required to develop
and maintain a written qualification program for individuals performing covered tasks on pipeline facilities.
The intent of this qualification rule was to ensure a qualified work force and to reduce the probability and
consequence of incidents caused by human error. It established qualification requirements for individuals
performing covered tasks, and amended certain training requirements in the hazardous liquid regulations.

This federal regulation became effective October 26, 1999. All operators were required to have a written
plan by April 27, 2001. All individuals performing a covered task were required to be Operator Qualified
by October 28, 2002, or be directed and observed by an individual of qualified status.

PHMSA defined a covered task as a pipeline function that must meet all four of the following criteria
(commonly known as the four part test) in order to be defined as a covered task:

1. It must be performed on a pipeline facility;

2. It must be an operations and maintenance task;
3. It must be performed as a requirement of 49 CFR 192 and 195;
4. It must affect the operation and integrity of the pipeline.

In addition, personnel must be trained and qualified on how to recognize and react to an abnormal
operating condition as defined in §§ 192.803 and 195.503. An abnormal operating condition means a
condition identified by the operator that may indicate a malfunction of a component or deviation from
normal operations that may:

(a) Indicate a condition exceeding design limits; or

(b) Result in a hazard(s) to persons, property, or the environment.

[Note: To be qualified, an individual must be able to properly perform assigned covered task(s) and be
able to recognize and react appropriately to any AOC that may (reasonably be expected to) be
encountered while performing the covered task – whether the condition arises as a direct result of his/her
work performance (e.g., be specific to the covered task being performed) or not (e.g., be generic in
nature, but still observable because the individual is present on site).]

An Operator must ensure that an individual possesses the Knowledge, Skills, and Abilities (KSA’s) for
such a covered task before they are allowed to perform that task. However, Direct Observation of an
unqualified individual(s) during the performance of a covered task by an individual who is qualified to
perform the task at hand is accepted. The observer must be in direct visual and verbal contact with the
individual(s) and must be able to take immediate and effective corrective action if incorrect procedures or
AOC’s are observed.

An Operator’s Written Qualification Plan shall include procedures on how the operator would:

- Identify All Covered Tasks

- Identify All Personnel Performing Covered Tasks
- Identify All Contractors Performing Covered Tasks

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 - Specify Qualification Process for Company Personnel
- Specify Operator Qualification Process for Contractors

Any and all company personnel performing a covered task needed to be identified in the OQ Plan.
Updated records should be kept for any employee performing a covered task, including a date of
evaluation or reevaluation for qualification of that employee, and identify all contractors performing
covered tasks. Any and all contractors performing a covered task on an operator's system should be
identified in the OQ Plan. Updated records should be kept for any contractor performing a covered task
on an operator's system, including a date of evaluation or reevaluation for qualification of that contractor.

The Plan must specify the Qualification Process for Company Personnel, and there
are several means of qualifying individuals performing a covered task. Some methods of qualification are:

1. Training
2. Oral testing
3. Written testing
4. Performance evaluations
5. On the job training, and simulations

Work history could no longer be used as a sole determinant of qualification as of October 28, 2002.
Whatever means of qualification a company chooses to use must be specifically detailed in that
company's OQ Plan as well as defining a basis for reevaluation.

Personnel who have been qualified and met the requirements set forth in 49 CFR 192 Subpart N and 195
Subpart G are not considered qualified for life. The evaluation process was not intended to be a onetime
qualification. After the initial qualification is performed, that individual shall be evaluated again for those
covered tasks for which they perform, at intervals as set forth by the operator. These intervals can vary for
each covered task due to the complexity of the task.

The Written Plan also must include provisions for evaluating an individual whose actions could have
contributed to an incident as defined in 49 CFR 192 or an accident as defined in 49 CFR 195. The
individual must be evaluated in order to surmise if the incident or accident was a direct result of his or her
failure to properly perform a covered task due to: incompetence, not properly evaluated initially, or the
inability to recognize and react to an abnormal condition. That individual may not be allowed to perform a
covered task until such has been re-evaluated by receiving additional training, instruction, and testing
necessary to perform a covered task. The employee can be either be re-instated after meeting PHMSA
requirements, or may be deemed unable to perform covered tasks due to physical or mental impairment.

Typical measurement of a gas or liquid in order to provide the company with data that determines the
amount of product flowing for sale is not typically considered a covered task due to the fact that it does
not meet the four part test.

1. Is it performed on a pipeline facility -Yes

2. Is it an operations and maintenance activity - Yes
3. Is it a requirement of 49 CFR 192 or 195 - No
4. Does it affect the operation or integrity of the pipeline - No

Therefore it does not meet the definition of a covered task, and personnel need not be qualified for that
task. However, if the measurement or calibration is being performed to determine data for sensing
pressure or flow that activates a safety overpressure or shutdown device to protect pipeline facilities, then

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 that individual must be qualified to be able to perform that task associated with those requirements, and
evaluated to recognize and react to any abnormal operating conditions that could arise associated with
that task.

Each operator shall evaluate daily tasks performed by measurement personnel, and subject that task to
the four part test. By performing this evaluation an operator will be able to determine what job functions
should be considered a covered task as defined by 49 CFR 192 or 195, and provide the proper training
and testing to qualify their personnel.

In conclusion, all operators subject to the jurisdictional oversight of the US DOT and/or their respective
State Agencies must ensure that company personnel, contractors, sub-contractors, etc. performing
covered tasks on jurisdictional facilities are trained and qualified in accordance with the rule, or only
allowed to perform those tasks while being directly observed by a qualified individual.

Operators of facilities that are subject to the provisions in 49 CFR 192 and 195 are also subject to many
other regulations that provide a curtain of safety to the general public. Other programs that are required
by PHMSA include but not limited to:

Drug and Alcohol Program

Pipeline Integrity Program
Public Awareness Program
Operations and Maintenance Plan
Corrosion Program

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