API RP 1161 - 2011 Recommended Practice For Operator Qualification
API RP 1161 - 2011 Recommended Practice For Operator Qualification
Qualification
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Recommended Practice for Operator Qualification
1 General
1.1 Purpose
The purpose of this Recommended Practice (RP) is to provide guidance for developing and maintaining a compliant
Operator Qualification (OQ) program.
1.2 Scope
Operators should be aware that the OQ rule is applicable only to United States Department of Transportation (DOT)
jurisdictional pipelines. For purposes of this document, the word “pipeline” is used interchangeably with pipeline,
pipeline facility and pipeline system and any and all jurisdictional pipeline components as defined in 49 CFR Part
195.
This document is written to provide guidance for achieving compliance with the regulation at the time of publication
and is comprised of two individual components: the Guidance Document and the API Covered Task List (Annex A).
A separate publication, the API Covered Task Standards, will contain guidance on the individual Covered Tasks.
This guidance will include knowledge and skill components, span of control and abnormal operating conditions.
Operators may choose to use all, part or none of this document. Additionally many components of this RP also
apply to Gas Transmission Lines regulated under 49 CFR 192. Therefore operators may choose to utilize the RP as
applicable for these lines.
2 Normative References
The following referenced documents are indispensable for the application of this document. For dated references,
only the edition cited applies. For undated references, the latest edition of the referenced document (including any
amendments) applies.
None
None
4 Introduction
4.1 Background
The DOT required that pipeline Operators develop a written qualification program to evaluate an individual’s ability to
perform covered tasks, and to recognize and react to abnormal operating conditions encountered while performing
covered tasks.
In accordance with the regulation, Operators were required to have written OQ programs no later than April 27,
2001, and were required to ensure individuals performing covered tasks were qualified by October 28, 2002. The
first edition of API Guidance Document for the Qualification of Liquid Pipeline Personnel was published in 2000 to
assist Operators in meeting these initial requirements.
The original purpose of API 1161 was to provide Liquid Pipeline Operators with a guidance document to aid in the
development of a written Operator Qualification (OQ) program to comply with the new OQ regulation (49 CFR Part
195 Subpart G) which became effective October 26, 1999. At that time, the preamble to the final rule was the only
guidance available to assist Operators with program development and program compliance. Since then, the
regulation has been revised. PHMSA has issued advisories, white papers, FAQs, protocols and other guidance
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documents; industry groups have formed and some have issued OQ standards; and Operators have gained
compliance experience as their programs have matured. Therefore, it is appropriate to revise API 1161 to reflect the
relevant additional information that was not available in 2000.
Each pipeline Operator is required to have and follow a written OQ program that includes provisions to address the
nine required elements of the OQ regulation. While the Operator has the flexibility to exceed the requirements of the
rule, it is important to note that any and all requirements included in the written program become enforceable.
Operators should define roles and responsibilities for the administration, management, and consistent
implementation of the OQ program. Clear responsibilities for implementing the elements of the program should be
established and communicated to affected individuals. Responsibilities associated with the OQ program may include
but are not limited to the following:
— training, as appropriate,
— recordkeeping,
The Operator may consider participating in an industry OQ group. These groups develop and update OQ guidance
materials, share best practices and interact with regulatory agencies.
5.3 Language
The Operator's program should include a policy on language to ensure effective communication where non-English
speaking individuals perform covered tasks. Options may include but are not limited to the following:
— maintain a single-language policy, whereby all individuals performing covered tasks speak the same language
(i.e. English);
— utilize bilingual individuals to interpret for non-English speaking individuals performing covered tasks;
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5.4 Program Improvement
While not specifically required by the regulation, the Operator may consider developing processes for periodic
review of the written program and auditing of the program implementation. Operators should determine the process
for incorporating program improvements based on the findings.
The purpose of a periodic review of the written program is to assure that it meets current regulatory compliance and
any additional needs of the Operator. The Operator has the flexibility to structure the review as formally or informally
as deemed necessary and should document the results and identify appropriate steps, if any.
The purpose of an internal audit is to assure the program is being implemented as written. The Operator has the
flexibility to structure the audit as formally or informally as deemed necessary and should document the results of the
audit and identify appropriate steps, if any.
6.1 General
The program shall identify and document covered tasks. A covered task is an activity, identified by the Operator that:
and
and
and
The four criteria listed above shall be referred to hereafter as the four-part test.
In developing the covered task list, the Operator shall consider tasks performed on the pipeline facility, regardless of
who performs them (employees, contractors, subcontractors or other entities such as other pipeline operators or
those with access to the operator’s equipment). For example, if an Operator contracts out pipeline repair activities,
those activities shall be considered in the identification of covered tasks.
The Operator has flexibility to determine how to accomplish covered task identification. The Operator should
document the method and justification for selecting covered tasks. Options for establishing a covered task list may
include but are not limited to the following two methods:
Industry and technical associations, qualification product providers, and others have developed covered task lists
through subject matter expert consensus. The Covered Task List developed by API is attached to this document as
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Annex A. The Operator should take additional steps if adopting such a list and at a minimum, should compare the
covered task list to its operations and maintenance activities in order to ensure completeness. The Operator has the
flexibility to combine or separate covered tasks as suitable to its operations and, if gaps are identified should apply
the four-part test to add or delete covered tasks as applicable.
An analysis of operations and maintenance activities may be used in the process of determining which activities
should be included in an Operator’s covered task list. Items to be considered when conducting activity identification
and analysis may include, but are not limited to the following:
It may be helpful to record each applicable activity on a master list, and document the answers to the four-part test
questions, adding justification notes as needed. This method of documentation will produce a list of covered and
non-covered tasks and may assist in regulatory and internal reviews. Subject matter experts, regulatory compliance
personnel, and others may be enlisted to assist in the identification and analysis of activities. Operators have the
flexibility to include additional tasks that do not meet the four-part test.
Operators should review the regulatory definitions of pipeline and pipeline facility. Components, piping, or equipment
that is physically connected to the pipeline or pipeline system (i.e. by wires, tubing, pipe, or by the pipeline right of
way) or that is connected by signals through the air are considered part of the pipeline facility.
A component, piping, or equipment disconnected and physically removed from the pipeline or pipeline system is not
considered part of the pipeline facility. A component that is disconnected, but not physically removed from the
pipeline facility, would meet the requirement of Part 1 of the four-part test.
Operations tasks may be defined as those activities associated with monitoring and controlling the transportation of
hazardous materials within a pipeline system. Maintenance tasks may be defined as those activities performed to
maintain, restore, replace, or relocate existing pipeline facilities.
6.3.3 Part 3—Is the task performed as a requirement of 49 CFR Part 195?
The Operator should review all Subparts of 195, applicable PHMSA Advisory Bulletins, and state and local
requirements to ensure completeness. Operations and maintenance tasks are not limited to those tasks addressed
in 195 Subpart F.
6.3.4 Part 4—Does the task affect the operation or integrity of the pipeline?
Operators shall consider tasks that, if performed incorrectly, could adversely affect the operations or integrity of the
pipeline, during or after the performance of the task. Operations include actions taken to facilitate storage or
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movement of product through a regulated pipeline. The integrity of the pipeline refers to the pipeline’s ability to
operate safely and to withstand the stresses imposed during operations.
As defined in the regulation, qualified means that an individual has been evaluated and can: (a) perform assigned
covered tasks and (b) recognize and react to abnormal operating conditions associated with those tasks.
The terms qualification and evaluation are frequently used interchangeably throughout the industry; however, they
are two distinct terms.
Qualification is the result of a process determined by the Operator that includes successful completion of task
specific evaluation(s) with the associated AOC’s, documentation and any other requirements as documented in the
program whereas an evaluation is a step in the qualification process.
7.1.1 Qualification
The Operator has several decision points when developing a Qualification process. At a minimum, consideration
should be given to the covered task, the individual or groups of individuals to be qualified and the type of
qualification. The resulting qualification process(es) should be documented.
7.1.1.1 Task
The Operator should review the covered tasks to determine the appropriate evaluation method(s) and other
qualification requirements. Things to be considered may include but are not limited to the following:
The Operator has flexibility to determine the evaluation methods and other qualification requirements for all
individuals who perform covered tasks and may utilize the same evaluation methods and other qualification
requirements for all groups of individuals (employees, contractors, subcontractors or other entities such as other
pipeline operators or those with access to the operator’s equipment) or, may establish different requirements for
different groups. The Operator may establish provisions in their Program to accept qualifications from other entities’
internal OQ Program.
Types of qualification should be considered when determining evaluation methods and other qualification
requirements. Requirements may differ by qualification type (e. g. initial qualifications, current qualifications prior to
an expiration date, qualifications that have exceeded an expiration date or qualifications which may require
additional actions as described in Elements 4 and 5).
7.1.2 Evaluations
As stated in the regulation, evaluation is the process, established and documented by the Operator, to determine an
individual’s ability to perform a covered task by any of the following:
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— written examination;
— oral examination;
— observation during:
— simulation;
NOTE Neither work performance history review nor observation of performance on the job can be used as a sole evaluation
method. These methods may be used in conjunction with other approved methods of evaluation.
Written and oral examinations consist of standard, pre-determined questions and should contain sufficient numbers
of questions to adequately measure the knowledge required to perform a covered task. A written examination is a
knowledge test in paper or electronic format, whereas oral examination is a verbal knowledge test. Consideration
should be made for the role of a proctor and/or evaluator to ensure tests are administered in a secure and controlled
setting.
Work performance history review (WPHR) is a structured, documented review of an individual’s task-related
performance records. WPHR was originally established to aid operators in transitioning their employees past work
experience to meet the requirements of the rule. If an operator chooses to use WPHR as an evaluation method; at a
minimum the following steps should be completed and documented:
— a search of existing records for documentation of an individual’s past satisfactory performance of a covered
task(s);
— verification that the individual’s work performance history contains no indications of substandard work or
involvement in an accident (Part 195), caused by an error in performing a covered task; and,
— verification that the individual has successfully performed the covered task on a regular basis prior to October
26, 1999.
Observation during performance on the job is a casual, unstructured observation where one or more of the following
are absent:
— an evaluator,
— documented criteria,
Observation during on the job training is a performance evaluation conducted at the conclusion of training on a
covered task. (See other forms of evaluation)
Observation during simulation can be any of several evaluation methods described as follows:
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— simulated scenario of a closed pipeline system such as those used in control centers,
— off the right of way using a mock up scenario to perform various covered tasks,
— demonstrating and communicating the intended performance of the covered task without physically touching the
equipment.
— Performance evaluations are formal, structured observations to measure skills and knowledge. An individual
independently performs a covered task in a real-time or simulated environment while an evaluator assesses
his/her skills based on a set of predetermined and documented criteria (such as a checklist).
— Professional certifications (e.g. NACE, ASNT, API, ANSI) that include evaluation.
Evaluations should assess an individual’s knowledge and skills necessary to perform the task. The Operator has the
option to develop internal evaluation materials or utilize material developed by third party organizations.
If developing internal evaluation material, the Operator may base the evaluations on Operations and Maintenance
procedures. If using third party vendors, it is the responsibility of the Operator to assess the vendors’ processes and
materials to ensure that all requirements are met.
The Operator may consider periodically reviewing and updating evaluations to ensure they meet requirements.
Items to be considered when developing an evaluation process may include but are not limited to the following.
— Pass/fail criteria:
— consequences of failure.
— The Operator may consider providing formal training for the evaluator to ensure he/she understands the
evaluation process and his/her role. The Operator may also consider if the evaluator should be qualified on
the task he/she is evaluating when the evaluation is performed on live pipe and there are no other qualified
individuals to direct and observe.
— Documentation requirements.
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7.1.6 Abnormal Operating Conditions (AOC)
As stated in the regulation, qualification shall include an evaluation of the individual’s ability to recognize and react to
AOCs associated with covered tasks.
The Operator has the flexibility to determine method(s) for ensuring individuals can recognize and react to AOCs.
These methods may include but are not limited to the following:
As defined in the regulation, an AOC means a condition identified by the Operator that may indicate a malfunction of
a component or deviation from normal operations that may:
Identifying AOCs for covered tasks includes but is not limited to:
— Analyzing the covered task procedures to identify any steps that, if performed incorrectly, could lead to a
release, overpressure or other potentially hazardous conditions. Upon identification of these steps, determine
and document the abnormal operating condition and the recognition and appropriate corrective response.
The Operator’s plan should address how the OQ rule applies to new construction. As defined by PHMSA, new
construction is the act of building a pipeline facility, or expanding an existing pipeline facility (as in looping a pipeline
segment, which may also be one to meet increased load requirements or to enhance reliability of the system) in
order to provide new service to a customer(s) or in order to meet increased demand. New construction ends when
the pipeline facility is being commissioned or during the act of connecting to an active pipeline (the tie-in).
The Operator’s program should include provisions for mergers and acquisitions and in such event shall ensure
qualified individuals perform covered tasks.
When individuals are included in the acquisition and will remain qualified under the acquired asset’s OQ program,
the Operator should make every effort to obtain that program prior to the acquisition, and review it for completeness
and acceptability. Sections to be reviewed may include but are not limited to the following:
— span of control,
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— requalification intervals,
— individuals’ qualifications,
— contractor management,
— evaluation criteria.
Once the program has been reviewed, the Operator has several options which may include but are not limited to the
following:
The Operator should document the process and actions taken during the merger or acquisition.
Even in the event no individuals are acquired with the merger or acquisition, the Operator should determine if
revisions or additional covered tasks or AOC’s are necessary due to differences in product transported, technology
or equipment.
The Operator may also review the acquired program for best practices and determine which, if any, components
should be incorporated.
8 Element 3: Allow Individuals that are Not Qualified Pursuant to the Regulation to
Perform a Covered Task if Directed and Observed by an Individual that is Qualified
Each task should be assessed to determine how many non-qualified individuals, if any, can perform the task while
being directed and observed by a qualified person. Criteria should be established for determining the ratio of
qualified vs. non-qualified individuals who can safely perform the covered tasks (span of control). Operators should
take into account the task’s complexity, criticality and normal working conditions when determining the maximum
span of control. Typical industry spans of control range from 1:0 thru 1:5. It is recommended the Operator not
exceed spans above 1:5. When establishing the maximum span of control, options to consider include, but are not
limited to the following:
The Operator may consider reducing span of control when actual jobsite conditions i.e. language barriers, weather
conditions, excess noise, limit the qualified individual’s ability to direct and observe nonqualified individuals. The
Operator may consider the impact of training on span of control. If the Operator sets the span of control for tasks at
1:0, then the Operator may consider including a provision in the program to allow a non-qualified individual to
perform covered tasks during on-the-job training.
In addition, the program should state that the qualified individual shall be in close proximity to the non-qualified
individual so that he/she may intervene if the task is being performed incorrectly and can respond to an AOC if one
should arise.
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9 Element 4: Evaluate an Individual if the Operator has Reason to Believe that the
Individual’s Performance of a Covered Task Contributed to an Accident/Incident as
Defined in the Regulation
9.1 General
Operators shall review an individual’s qualification upon determination that the individual’s performance of covered
task(s) contributed to an accident or incident.
If the Operator determines that an individual’s performance of a covered task contributed to a PHMSA defined
accident, the Operator should determine if the covered task(s) was performed improperly due to the following:
— deficiency in procedure,
The Operator should determine and execute appropriate action(s) to ensure qualification and effectiveness.
Appropriate actions to be taken may include, but are not limited to the following:
— no action required.
Operators should document the results of the review including any actions taken.
10 Element 5: Evaluate an Individual if the Operator has Reason to Believe that the
Individual is No Longer Qualified to Perform a Covered Task
10.1 General
Operators shall review an individual’s performance of covered tasks if there is reason to believe the individual should
no longer be qualified.
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10.2 Guidance on Determining if an Individual Should No Longer be Qualified
Operators should develop a process to determine if and when an individual is no longer qualified to perform a
covered task. Reasons an individual may no longer be qualified, other than an accident or incident as defined by
DOT Part 195, may include, but are not limited to the following:
— extended leave;
The Operator has the flexibility to establish a policy that applies to all affected individuals, or may choose to
determine qualification on an individual basis, or a combination of both. It may be helpful to consider the following.
— If tasks were performed improperly, does the individual lack knowledge, skill or ability?
— Did the reason for leave affect the individual’s ability to perform covered tasks?
— How much experience does the individual have at performing the covered tasks?
— How much time elapsed since the last performance of the covered task?
In the event the individual is no longer qualified, the Operator may consider additional actions, which may include but
are not limited to the following:
— training,
— re-evaluation,
— procedure review,
— no action required.
11 Element 6: Identify Those Covered Tasks and the Intervals at Which Evaluation of the
Individual’s Qualifications is Needed
11.1 General
Operators should establish and document re-evaluation intervals for each covered task.
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11.2 Guidance on Developing Re-evaluation Intervals
When developing intervals, the Operator has the option of utilizing evaluation intervals established by an industry
association or other entity or developing their own intervals. However, an evaluation interval of 36 months is
recommended based on current accepted practice. An operator may choose to extend this timeframe as needed for
scheduling flexibility. Any extension should be documented in the Operator’s Plan. If the Operator chooses to adopt
an industry developed interval, the Operator should review the interval to ensure the requirements of their Program
are met.
When developing intervals internally, the Operator should develop and document the rationale used to determine the
intervals and may consider the following:
— criticality of the task (how does the task impact safety and integrity of the pipeline facility?);
The Operator may consider establishing a method of notifying individuals prior to the expiration of the qualification.
12.1 Guidance on Developing Processes to Communicate Changes that Affect Covered Tasks
Changes that affect covered tasks shall be communicated. The Operator should have processes in place for
communicating the change to the affected individuals.
Examples of changes that affect covered tasks may include the following:
— re-evaluation intervals;
— span of control.
Significant changes to covered tasks may necessitate additional evaluation to maintain qualification.
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13 Element 8: Provide Training, as Appropriate, to Ensure that Individuals Performing
Covered Tasks Have the Necessary Knowledge and Skills to Perform the Tasks in a
Manner that Ensures the Safe Operation of Pipeline Facilities
13.1 General
The Operator should address the role of training in the qualification of individuals.
It is important to note, that the term “training” is often used incorrectly in reference to evaluation and qualification.
Training is the act of facilitating the learning and development and improvement of new and existing knowledge and
skills and not the evaluation or qualification of those knowledge and skills.
There may be circumstances that require training to ensure individuals have the knowledge and skills required for
qualification.
— initial qualification;
— suspension or disqualification;
— failed evaluation.
— self study.
14.1 General
Operators are required to identify significant modifications that would require notification and submission to PHMSA
and appropriate state regulatory agencies.
Operators should determine what changes would be considered significant changes to the OQ Program. Examples
of changes that may be considered significant include:
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— evaluation process;
— qualification process;
— wholesale changes made to the Operator’s program, e.g. consolidation of programs following a merger or
acquisition, changes to roles and responsibilities or other changes the Operator deems significant.
Operators should send notifications of significant modification of an OQ Program to the OPS Information Resource
Manager by either e-mail or mail as follows.
The operator should submit the complete Plan accompanied by revision/change log and effective date of change(s).
The plan should be notated such that changed areas of the plan can be readily identified. Employee-specific
information (i.e. social security numbers) and testing material do not need to be sent.
3) data/email/phone number,
4) commodity (gas/liquid/both),
NOTE Operators subject to pipeline safety regulations (add regulatory reference) by State agencies are required to send OQ
notifications directly to each State agency.
14.4 Recordkeeping
In addition to elements 1 through 9, the rule requires that the Operator maintain the following records for all
individuals performing covered tasks:
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— identification of qualified individual(s),
— qualification method(s).
Records supporting an individual’s current qualification shall be maintained while the individual is performing the
covered task. Records of prior qualification and records of individuals no longer performing covered tasks shall be
retained for a period of five years. It is important to note that the five years begins on the last date the qualification
was valid.
Operators may consider developing and documenting a process that ensures individuals performing covered tasks
have valid qualifications. Examples of validation methods may include but are not limited to:
— electronic records,
— ID Cards.
Qualification records may be maintained by the Operator or a third party. It is important to note that different
methods may be used to validate qualification for employees, contractors, subcontractors or other entities.
The Operator may consider maintaining additional records to demonstrate compliance with the program. While this
list of records is not officially required by regulation, many are integral to the OQ program:
— documented history of written program and all program revisions including covered task changes;
— evaluation criteria;
— span of control;
— applicable training;
— feedback from field personnel, accident and incident investigations, near miss programs or other sources that
could enhance the OQ program, such as AOCs, evaluations and training;
— history file of checklist used for performance verifications and written/oral exams;
— log of revision.
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Annex A
Covered Task List
The Covered Tasks listed below were developed by API and may be adopted by the Operator as described in
section 6.2.1 of this document.
COVERED
TASK COVERED TASK NAME
NUMBER
3.0 Obtain a Voltage and Current Output Reading from a Rectifier to Verify Proper Performance
7.2 Prepare Surface for Coating Using Hand and Power Tools
7.4 Prepare Surface for Coating by Abrasive Blasting Methods Other Than Water
11.0 Monitoring and Controlling the Injection Rate of the Corrosion Inhibitor
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COVERED
TASK COVERED TASK NAME
NUMBER
22.2 Inspect, Test, and Calibrate HVL Tank Pressure Relief Valves
27.1 Routine Inspection of Breakout Tanks (API 653 Monthly or DOT Annual)
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COVERED
TASK COVERED TASK NAME
NUMBER
40.1 Full Encirclement Welded Split Sleeve (Oversleeve, Tight Fitting Sleeve, etc.)
42.7 Welding
43.3 Monitor Pressures, Flows, Communications and Line Integrity and Maintain Them Within Allowa-
ble Limits on a Liquid Pipeline System (Control Center)
43.4 Manually or Remotely Open or Close Valves or Other Equipment on a Liquid Pipeline System
(Control Center)
44.3 Inspect, Test and Maintain a Liquid Pipeline Leak Detection Flow Computer
44.4 Inspection, Testing, Corrective and Preventative Maintenance of Tank Gauging for Leak Detection
44.7 Inspect, Test and Maintain Gravitometers/Densitometers for Hazardous Liquid Leak Detection
63.3 Monitor Pressures, Flows, Communications and Line Integrity and Maintain Them Within Allowa-
ble Limits on a Liquid Pipeline System (Field)
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COVERED
TASK COVERED TASK NAME
NUMBER
63.4 Manually or Remotely Open or Close Valves or Other Equipment on a Liquid Pipeline System
(Field)
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