Request for comments following public meeting 
At least 100 individuals participated in the public meeting on December 15, 2005. Based 
on discussions at this meeting and at the meeting of the pipeline safety advisory 
committees earlier in the week, PHMSA has revised the attached concept paper on 
addressing operator qualification (OQ) issues. As announced at the public meeting, 
PHMSA continues to seek comments on the two major areas of the public meeting as 
follows: 
• Submit comments on the progress of OQ programs by January 13, 2006 in order 
to be considered in the preparation of the report to Congress. 
• Submit comments on the potential for strengthening OQ programs, including 
comments on the revised concept paper, by February 10, 2006. 

A Concept 
To Address Remaining Operator Qualification (OQ) Issues 
Revised Following Public Meeting on December 15, 2005 
Regulatory – PHMSA is considering three changes to regulations: 
$ Training B The OQ regulations now require only that an OQ program include training Aas 
appropriate@. PHMSA is considering providing additional specificity. In addition to 
including training Aas appropriate,@ an OQ program would have to include training in 
particular circumstances. These circumstances are as follows: 
- an individual has never performed an assigned covered task; 
- there has been substantial change to a covered task, such as the use of new 
equipment or procedures that makes previous training no longer adequate; or 
- an individual has failed to requalify on a covered task after an accident. 
In addition, an operator would have to ensure training in damage prevention for 
individuals performing excavation for the operator. Excavation damage remains a major 
concern in pipeline failures. 
$ Reevaluation intervals B The OQ regulations now require an operator to identify the tasks 
for which reevaluation is required and the intervals for reevaluation. PHMSA is 
considering requiring an operator to set maximum intervals for reevaluation for every 
task. These intervals would not exceed five years. Operators may find a shorter absolute 
maximum interval of three years easier to administer. 
$ New construction B PHMSA is considering a change to the pipeline safety standards (not 
necessarily the OQ regulations) to require an operator to have a process to verify the 
integrity of new construction. Errors in the construction of a pipeline can result in 
failures, costly repairs, and increased maintenance costs. The process for verifying 
integrity of new construction could include: 
- Using accepted quality control practices during construction. 
- Including new construction tasks in OQ programs. 
- Using integrity verification methods such as pressure testing and nondestructive 
testing. 
Non-regulatory - Other clarifications, possibly by advisory bulletin, would enhance an 
operator=s understanding of the requirements: 

$ Emergency response - Clarify the requirement to include emergency response tasks in 
OQ programs. An operator needs to have qualified personnel available to handle actions 
necessary to ensure pipeline safety. 
$ Abnormal operating conditions B Clarify the need for an operator to identify and 
periodically review the operator=s list of abnormal operating conditions to aid in 
compliance.