Serving the energy industry for over 30 years
By - Jon Brown

Operator Qualification and Control Room Management for Pipelines
Designing an OQ Program, CRM Lessons Learned, PHMSA Enforcement Trends, Metrics and Guidance
July 26, 2019 | Denver, CO

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Pipeline and Hazardous Materials Safety Administration (PHMSA) strongly enforces its Operator Qualifications (OQ) regulations and has developed enforcement guidelines and strategies. Thus, it is vital for operators to understand and be totally conversant on these rules and guidelines. OQ is essential to overall pipeline safety performance and is critical in preventing system failures, injuries, property damage, and other serious consequences. OQ is not intended to be a one-time event, but a continual process. All pipeline operators subject to Parts 192 and 195 are covered by the OQ rule and are responsible for ensuring that any employees, contractor employees and subcontractor employees who perform covered tasks on their pipeline systems are qualified in accordance with the rule. Operators must develop and maintain a fully qualified, compliant workforce.

Additionally, PHMSA published final regulations on December 3, 2009, for Control Room Management (CRM). The regulations prescribe extensive safety requirements for controllers and control rooms that remotely monitor and control liquid and gas pipelines regulated under 49 C.F.R. Parts 192 and 195. Owners and operators of liquid and gas pipelines have significant and ongoing regulatory responsibilities under the CRM Rule, including developing, implementing and documenting policies and procedures, training personnel, and incorporating CRM requirements into operations across pipeline systems.

This one-day course will provide guidance on all components of OQ regulations. PHMSA enforcement trends will be discussed. Attendees will leave the course with knowledge of the internal and external audit process and an interactive training session will be used to review the learning outcomes of this course. The course will also review Control Room Management regulations and specific issues with implementation. Attendees will be instructed on how to reach the next level of continual improvement with their CRM plan, development of meaningful metrics, and ensuring ongoing implementation of the plan. PHMSA audit findings and trends will be shared and discussed. The instructor is a pipeline industry professional who has deep expertise in the requirements and day-to-day working experience with best-in-class programs.

The OQ portion of the course will take place in the morning and the CRM portion of the course will take place in the afternoon. Either or both tracks may be attended, please make your choice on the registration page.

Note: This course does not provide OQ certification for covered tasks. It is intended as a legal/regulatory compliance overview for attorneys, compliance managers and OQ program managers

Learning Outcomes 

  • Differentiate between federal regulations, state requirements, and the ASME B31Q task list for Operator Qualification (OQ) programs
  • Review increasing scope of covered tasks
  • Discuss intricacies and best practices of compliance documentation
  • Discuss the recent PHMSA enforcement trends for OQ programs
  • Demonstrate how to best prepare for OQ, operations and maintenance audits
  • Review knowledge of CRM regulations
  • Review the CRM audit process
  • Discuss techniques and tips for identifying and addressing deficiencies in your CRM plan or CRM implementation
  • Identify how to best prepare for a CRM audit interview
  • Discuss the role of compliance managers and in-house counsel in managing audits and achieving and demonstrating compliance
  • Discuss controlling and protecting company records while demonstrating compliance



EUCI has been accredited as an Authorized Provider by the International Association for Continuing Education and Training (IACET).  In obtaining this accreditation, EUCI has demonstrated that it  complies with the ANSI/IACET Standard which is recognized internationally as a standard of good practice. As a result of their Authorized Provider status, EUCI is authorized to offer IACET CEUs for its programs that qualify under the ANSI/IACET Standard.

EUCI is authorized by IACET to offer 0.8 CEUs for this event.


Requirements for Successful Completion of Program 

Participants must sign in/out each day and be in attendance for the entirety of the course. 

Instructional Methods 

Case studies, PowerPoint presentations and classroom exercises will be used in the instruction of this course. 


Friday, July 26, 2019

7:30 – 8:00 a.m. :: Registration and Continental Breakfast

8:00 a.m.-12:00 p.m. :: Operator Qualifications

Operator Qualification – Background and Overview 

  • History 
    • Qualification standards before the OQ rules went into effect 
    • Development and promulgation of the OQ rules 
  • Overview of the federal regulatory requirements 
  • ASME B31Q Task List 
  • Developments in state OQ requirements 

The Details: Guidance on the Requirements 

  • Qualifications 
  • Employee OQ 
  • Contractor qualification 
  • Span of control 
  • Identifying covered tasks 
  • Documents and procedures 
  • Recordkeeping 
  • Abnormal operating conditions and emergencies 
  • Maintenance vs new construction 
  • Training  
  • Re-evaluation intervals 

Changes coming for OQ: Proposed Rulemaking & Legislative Changes

Internal and External Audits 

  • Preparing for an audit 
  • Scope of OQ agency audits 
  • Recent audit results 

What OQ Training Changes are Needed

OQ Interactive Training and Review 

12:00 – 1:00 p.m. :: Group Luncheon

1:00 – 5:00 p.m. :: Control Room Management

CRM Background & Overview

  • NTSB Study and recommendations
  • Rulemaking
  • Advisory bulletins
  • Applicability and exclusions
  • Regulations vs. best practices

Required Documents & Procedures

  • Normal and abnormal operating conditions and emergencies

Adequate Information

  • Display standard
  • Point to point verification
  • Communication and training: test and verify
  • Backup
  • SCADA systems
  • Shift change and hand-over

Fatigue Mitigation & Managing Hours of Service (Hos) Requirements

  • HoS rules and emergency deviations
  • Workload analysis
  • Fatigue mitigation strategies and documentation issues
  • Incident/near miss investigation
  • Research and best practices
  • Metrics and performance measurement

Alarm Management

  • Defining “safety related” alarms
  • Developing and validating alarm philosophy
  • Managing and correcting alarm set points
  • Alarm bundling and overload
  • Benchmarking and performance metrics
  • Addressing deficiencies
  • Managing pipelines and multiple SCADA systems
  • Documentation or periodic, monthly and annual requirements

Change Management

  • Understanding the rule and how it applies beyond the control room
  • Engaging stakeholders

New CRM Regulations

Review & Conclusion


Charlene B. Wright, Managing Member, Wright & Associates PLLC 

Ms. Wright advises clients on complex federal and state laws, agency regulations and industry standards including the Pipeline Safety Act, Federal Hazardous Materials Transportation law, Occupational Safety and Health Act, (OSHA) Toxic Substances Control Act, (TSCA), the PCB Mega Rule, LP Gas Code and NFPA Standards. 

She represents clients in compliance, enforcement and permitting matters include those under the authority of the U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA), Federal Energy Regulatory Commission (FERC), Bureau of Ocean Energy Management Regulation & Enforcement (BOEMRE), U.S. Environmental Protection Agency (EPA), Federal Motor Carrier Safety Administration (FMSCA), United States Coast Guard, (USCG), State and Local LP Gas Agencies, the Texas Railroad Commission, and Transport Canada. Her experience includes drafting comments to proposed rules impacting the industry and analysis of legislative initiatives. 

Ms. Wright defends energy clients in litigation resulting from rupture, leak, fire and explosion in state and federal courts. She has handled litigation in California, Colorado, Illinois, Kansas, Michigan, Minnesota, Missouri, New Mexico, New Jersey, New York, North Carolina, Ohio, Oklahoma, Oregon, Utah, and Wisconsin. 



EUCI Office Building Conference Center

4601 DTC Blvd, B-100

Denver CO, 80237


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