What Makes a Pipeline Task "Covered?" Unraveling the 4-Part Test

Ever wondered why backfilling on an active pipeline requires Operator Qualification (OQ), but backhoe maintenance does not? Or why leak investigation is a covered task, but exhausting leaked gas isn’t?

What is the Four-Part Test?

Backfilling on an active pipeline and leak investigation are considered covered tasks and require Operator Qualification (OQ) because they are identified by Operators as passing the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) “four-part test.” According to PHMSA, any activity that meets all parts of this test, as defined in 49 CFR 192.801 (for natural gas) or 49 CFR 195.501 (for hazardous liquid), is considered a covered task.

The four parts, as defined in both regulations, identify that a task is covered if it:

(1) Is performed on a pipeline facility
(2) Is an operations or maintenance task
(3) Is performed as a requirement of 49 CFR 192 or 49 CFR 195
(4) It affects the operation or integrity of the pipeline

Let’s look at backfilling as an example and examine how it meets each of the four parts:

(1)PHMSA defines a pipeline facility as an in-service pipeline involved in the transportation of product. Backfilling is performed on a pipeline facility every time an in-service pipe is buried underground

(2)It could be performed as either part of operations or maintenance (like after an inspection for coating damage on an exposed pipe)

(3)It’s performed as a requirement of 192 and 195 regulations (for example, see 49 CFR 192.319 (b) and 49 CFR 195.252)

(4)Backfilling affects both the operation and integrity of the pipeline. An incorrectly backfilled pipe is at risk of being damaged by rocks or foreign materials, potentially leading to a product release

Because it meets these requirements, backfilling is considered a covered task. Workers who are not qualified to perform backfilling could harm personnel, property, and the environment if they perform this task incorrectly.

Requiring OQ for a task like backfilling is intended to reduce pipeline accidents and incidents by ensuring that individuals who perform covered tasks on pipeline facilities are trained and qualified.

So, why isn’t backfilling an inactive pipeline considered a covered task? While it is an important process that requires skill and knowledge, it fails on several grounds. Firstly, it’s not performed on an active pipeline as defined by PHMSA. Likewise, an inactive pipeline does not pose a risk of immediate product release due to damage during backfilling.

Helpful Resources for Identifying Covered Tasks

According to PHMSA’s OQ FAQ #9[i], industry standards, like the American Society of Mechanical Engineers’ B31Q: Pipeline Personnel Qualification (ASME B31Q) or the American Petroleum Institute RP 1161: Pipeline Operator Qualification (API 1161), provide a useful starting point for Operators in identifying industry-accepted covered tasks. These standards not only provide a list of ready-to-use covered tasks, but also give guidance and methodologies for developing a full OQ program, from identifying covered tasks to determining the AOCs associated with those tasks. When Operators use these resources for covered task development, they should note that in their written OQ Program.

However, according to PHMSA, the standards provided in ASME B31Q and API 1161 aren’t the final word. Regulators and auditors may ask whether Operators consider certain activities to be covered tasks. Even if an activity performed on the Operator’s pipeline facility is not listed in one of these standards, Operators must evaluate it and determine if it is a covered task using the four-part test. If it is, they’re required to ensure anyone performing it is doing so according to the Operator’s written qualification program.

Next Steps in Your OQ Journey

Identifying covered tasks isn’t the end of the road, though. Once you’ve identified your covered tasks, you’ll need to provide training, evaluate your workers, and collect accurate and timely documentation.

Fortunately, EWN is here to help. EWN has over 30 years of experience supporting operators along their OQ journey. We offer a wide range of solutions, including:

• A flexible compliance management platform that can digitally support your OQ program
• Standardized online training and evaluations that you can use or customize for your own task list
• Expert consultants who can provide additional support for building and maintaining your OQ program

Looking to get started? Click the button below to get your journey started with EWN!

[i] https://www.phmsa.dot.gov/pipeline/operator-qualifications/oq-frequently-asked-questions