What OQ Records Must Be Kept for PHMSA Compliance?

Employee Information

Every OQ record should begin with clear identification of the individual. The following employee information should be included:

• Employee name
• Employee ID or unique identifier
• Employer / company
• Job title or position

Covered Task Information

Records must identify the specific covered task for which the individual is qualified. Covered task documentation should include:

• Covered task ID or number
• Covered task description
• Procedure or standard associated with the covered task

Qualification Information

This is the core of the OQ record — the documentation that demonstrates the individual was properly evaluated. Qualification records must include:

• Date of qualification
• Method of qualification (written test, oral test, observation, work performance, simulation, previous experience, or combination)
• Name of evaluator
• Evaluation method used
• Evaluation results (pass/fail)
• Any limitations or conditions on the qualification

Requalification Information

Operators must track requalification as a separate and ongoing part of the OQ record. Requalification documentation should include:

• Requalification interval
• Requalification due date
• Date of requalification
• Method of requalification
• Evaluator for requalification
• Requalification results

Training Records (If Applicable)

When training is part of the qualification process, training records must be maintained and linked to the qualification. Training documentation should include:

• Training course name
• Training date
• Training provider
• Documentation of completed training
• Link between training and covered task qualification

Supporting Documentation and Record Retention

The qualification record should be accompanied by the documentation that supports it. This includes:

• Evaluation forms
• Test results
• Observation checklists
• Training certificates
• Qualification cards or documentation
• Any supporting documentation used to qualify the individual

Qualification Status Tracking

Operators should track the current qualification status for each individual and each covered task. Valid status categories include:

• Qualified
• Not Qualified
• In Training
• Expired
• Pending Evaluation
• Suspended or Revoked

Why These Records Are Important

PHMSA inspectors are not just verifying that a person is qualified — they are verifying that the operator has a documented and controlled Operator Qualification program. The records must demonstrate who was qualified, for which covered tasks, how they were evaluated, who performed the evaluation, and when requalification is required.

If these records cannot be produced during an inspection or audit, the operator may not be able to demonstrate compliance with Operator Qualification requirements — even if the underlying qualification work was actually performed.

Best Practices for OQ Recordkeeping

Organizations with well-managed OQ programs follow these practices to stay audit-ready:

• Maintain a master list of covered tasks
• Maintain a list of qualified individuals by covered task
• Track qualification and requalification dates
• Store all supporting documentation alongside the qualification record
• Maintain full qualification history for each individual
• Keep records organized and easily retrievable
• Periodically review OQ records for expiration and completeness

How Cambri Compliance Helps

Cambri Compliance helps organizations manage Operator Qualification records by tracking covered tasks, qualification dates, requalification due dates, evaluation records, and supporting documentation in one centralized system. This helps organizations maintain organized, traceable, and audit-ready Operator Qualification records for PHMSA compliance.