Key Takeaways
- A covered task is any operations or maintenance task performed on a pipeline facility that affects pipeline safety.
- Covered tasks must be performed by qualified individuals under PHMSA's Operator Qualification rule.
- Operators are responsible for identifying and documenting all covered tasks applicable to their system.
- Each covered task requires qualification records, including evaluation method, evaluator name, and requalification due date.
The Definition: What Makes a Task "Covered"?
A covered task is an operations or maintenance task performed on a pipeline facility that affects pipeline safety and must be performed by a qualified individual under the Operator Qualification rule.
The definition comes from 49 CFR Part 192 (gas pipelines) and Part 195 (liquid pipelines). To qualify as a covered task, the activity must be performed on a pipeline facility, affect the safety of pipeline operations, be part of operations or maintenance work, and not be a one-time task.
Operators are responsible for developing their own covered task lists and making sure the list reflects the actual work being performed on their system.
Examples of Covered Tasks
Common examples of covered tasks in pipeline operations and maintenance include:
- Leak survey
- Pressure testing
- Meter installation
- Regulator inspection
- Valve operation
- Odorization
- Pipeline patrols
- Maintenance activities
- Plastic fusion
- Welding
- Line locating
Why It Matters: Qualification Is Required Before the Work
If a task is classified as a covered task, only a qualified individual may perform it. That means the individual must have been evaluated using an accepted method — written test, oral exam, observed performance, simulation, or demonstrated prior experience — and a record of that qualification must exist.
An individual performing a covered task without a current qualification on record is both a safety issue and an audit finding. During PHMSA inspections, inspectors will ask to see qualification records for individuals who performed covered tasks — and those records need to show the task, the evaluation method, the evaluator, and the qualification date.
Covered Tasks Apply to Contractors Too
The covered task requirement applies to anyone performing the work on the operator's system — including contractors. Operators cannot simply assume that a contractor's OQ program covers their specific covered task list. The operator is responsible for verifying that contractor personnel performing covered tasks are qualified and that records exist to demonstrate it. Cambri Compliance helps organizations track covered tasks, qualification records, and requalification due dates to support PHMSA compliance.
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