ASME B31Q and Pipeline Operator Qualification (OQ)

Short answer: ASME B31Q, Pipeline Personnel Qualification, is a voluntary consensus standard that tells pipeline operators how to identify covered tasks and qualify the people who perform them. The legal requirement in the USA is different: the PHMSA Operator Qualification (OQ) rule in 49 CFR Part 192 Subpart N (gas) and Part 195 Subpart G (liquids). B31Q has not been incorporated by reference into those rules, so operators use it as a tool to build a compliant OQ program, not as a substitute for one.

Three things get confused on pipeline jobs: the federal OQ rule, the ASME B31Q standard, and NDT personnel certification under ASNT SNT-TC-1A or ANSI/ASNT CP-189. Each answers a different question. The OQ rule asks whether the individual is qualified to perform a specific operations or maintenance task on this operator's pipeline and to recognize and react to abnormal operating conditions. B31Q offers a structured, industry-agreed way to answer that question. NDT certification asks whether a technician is trained, experienced and examined in a test method under an employer's written practice. This guide explains each layer, how they fit together for inspection contractors, what records an operator and a regulator expect, and where Canada differs.

What ASME B31Q is, and what it is not

ASME B31Q is the pipeline personnel qualification standard published by ASME. ASME describes its scope as setting requirements for identifying covered tasks that affect the safety or integrity of pipelines, qualifying individuals to perform those tasks, and managing those qualifications over time. It is written for both liquid and gas pipeline systems and is aimed at operators, contractors, service providers and regulators. The current edition listed by ASME is B31Q-2025; check the ASME catalogue for the edition your program references before you rely on any specific provision.

The standard grew out of the regulatory process. After PHMSA's 2003 public meetings on the OQ rule left a set of issues unresolved, including evaluation of knowledge, skills and abilities, re-evaluation intervals, direction and observation of non-qualified individuals, treatment of training, abnormal operating conditions and the extent of documentation, an ASME committee with operators, contractors and government participants began work on a consensus document. According to a 2013 PHMSA presentation to state pipeline safety staff, the first edition was published in 2006 and the second in 2010, and a standing committee has maintained it since.

What B31Q is not: it is not a federal regulation, it is not a certification scheme for individuals, and it does not certify NDT technicians. PHMSA enforcement guidance describes B31Q as a non-mandatory standard that has not been incorporated by reference into the pipeline safety regulations. An operator can adopt it voluntarily, in whole or in part, and once its written program says it follows B31Q, inspectors will expect the program to do what it says. That is the practical trap: a standard you volunteer to follow becomes part of the procedure you are inspected against.

The PHMSA presentation lists the main ways B31Q goes beyond the regulation: its scope is framed as safety and integrity rather than only operations and maintenance; it can cover new construction; it expects a measure of program effectiveness; it gives training a defined role; it calls for additional records; and it sets expectations for evaluators. Each of those choices adds work, which is why some operators adopt only the B31Q covered task list and build the rest of the program directly on Subpart N.

What the federal OQ rule actually requires

The OQ rule is short, and its core is a four-part test. Under 49 CFR 192.801, a covered task is an activity, identified by the operator, that meets all four conditions: it is performed on a pipeline facility; it is an operations or maintenance task; it is performed as a requirement of Part 192; and it affects the operation or integrity of the pipeline. Section 195.501 applies the same four-part test to hazardous liquid pipelines. If any one condition fails, the activity is not a covered task under the rule, though it may still be governed by other requirements.

Section 192.803 defines the vocabulary. An evaluation is a documented process, established by the operator, for determining whether an individual can perform a covered task; methods named in the rule include written and oral examination, work performance history review, observation of on-the-job performance, on-the-job training or simulations, and other forms of assessment. Qualified means the individual has been evaluated and can perform the assigned covered tasks and recognize and react to abnormal operating conditions. An abnormal operating condition is a condition the operator identifies that may indicate a malfunction of a component or a deviation from normal operations that may exceed design limits or create a hazard.

Section 192.805 lists what the written qualification program must provide for:

• identifying covered tasks;
• ensuring through evaluation that individuals performing covered tasks are qualified;
• allowing individuals who are not qualified to perform a covered task only if they are directed and observed by a qualified individual;
• evaluating an individual if there is reason to believe the individual's performance of a covered task contributed to an incident reportable under Part 191;
• evaluating an individual if there is reason to believe the individual is no longer qualified to perform a covered task;
• communicating changes that affect covered tasks to the individuals performing them;
• identifying which covered tasks need re-evaluation and at what intervals;
• providing training, as appropriate, so that individuals have the knowledge and skills to perform covered tasks safely;
• notifying the regulator if the operator significantly modifies a program that has already been verified for compliance.

Section 192.809 contains the transition dates. Programs had to be in place by April 27, 2001 and initial qualification completed by October 28, 2002. Work performance history review could be the sole evaluation method only for individuals who were already performing a covered task before October 26, 1999; after October 28, 2002 it can no longer be the only method. Since December 16, 2004, observation of on-the-job performance cannot be the sole method either. In practice that means a modern OQ evaluation combines at least two methods, typically a knowledge check and a performance check.

B31Q versus the OQ rule: side by side

The quickest way to see the relationship is to compare the two on the points that matter in an audit. The table summarises the regulation as written in Subpart N and the B31Q characteristics PHMSA has described publicly; where B31Q content is not public, the table says so rather than guessing.

PHMSA's position on task lists is the single most important point for operators. Its guidance says an industry standard such as B31Q or API RP 1161 can be a useful starting point for identifying covered tasks, but the absence of a task from that list does not mean it is not a covered task. The four-part test governs. An operator that adopts the B31Q list and deletes an existing covered task because it does not appear there has created a compliance gap, and the 2013 PHMSA presentation warned operators that they would be inspected against both their adopted list and any task that meets the four-part test.

Where NDT and inspection work fits

NDT technicians and inspectors on pipelines meet OQ in two different ways, and the distinction matters for who pays for what qualification. During new construction, the OQ rule's four-part test is generally not met because construction is not an operations or maintenance task. Construction NDT is instead governed by the construction subparts of the regulations. For gas pipelines, 49 CFR 192.243 requires nondestructive testing of welds to be performed under written procedures by individuals trained and qualified in those procedures and with the equipment used, and requires records of the testing to be retained. Most operators meet that requirement by specifying ASNT SNT-TC-1A or CP-189 certification in the contract, often with API 1104 acceptance criteria for girth welds. If an operator has adopted B31Q including its construction provisions, it may also choose to treat some construction tasks as qualification tasks; that is the operator's decision.

On an operating pipeline the picture changes. An integrity dig, an in-service repair inspection, a cathodic protection reading or a coating assessment may be an operations or maintenance task required by Part 192 or 195 that affects the integrity of the pipeline. If the operator identifies it as a covered task, the person performing it must be OQ-qualified for that task under the operator's program, or directed and observed by someone who is. Holding an ASNT Level II certificate in UT does not, by itself, make a technician OQ-qualified for a covered task, and an OQ qualification does not make anyone an NDT Level II. They are different credentials answering different questions.

Operators handle this in different ways. Some write NDT certification into the OQ evaluation itself, so that a current SNT-TC-1A certificate is a prerequisite and the OQ evaluation then checks task-specific knowledge, such as the operator's dig procedure and its abnormal operating conditions. Others accept qualifications from a third-party OQ evaluation provider whose task modules map to their own covered task list. Either way, the operator owns the decision. Contractors cannot qualify themselves into an operator's program; they can only show evidence the operator's program accepts.

A worked example: an integrity dig on a gas transmission line

Consider, qualitatively, an operator excavating a gas transmission pipe to examine an anomaly reported by an in-line inspection run. The work includes excavation, coating removal, visual examination, measurement of external corrosion, ultrasonic thickness readings and possibly magnetic particle examination for cracking, then recoating and backfill. The operator's integrity management procedures require the examination, and the outcome decides whether the pipe stays in service at its current pressure.

Run the four-part test task by task. The examination is performed on a pipeline facility, it is a maintenance activity, it is required by the operator's obligations under Part 192, and its results affect the integrity decision. Under most operators' programs, the measurement and documentation of external corrosion, and possibly the coating application, will be identified as covered tasks. The operator then expects each person performing those steps to be qualified for those specific tasks, with the evaluation date and method on record, or to be directed and observed by a qualified person within the program's span-of-control limits.

Now layer the NDT certification. The UT thickness readings and MT examination should be performed by technicians certified in those methods under their employer's written practice, using a procedure approved by a Level III and calibrated equipment. The operator's OQ program confirms the technician can do the task on this pipeline and recognise abnormal conditions, such as a gas odor in the bell hole or a coating condition that suggests a different damage mechanism. The NDT certification confirms the technician can produce valid measurements. A file that has one without the other is incomplete. Where the dig reveals something that needs an engineering assessment of remaining strength, that assessment is commissioned by the operator under its integrity management program; it is not part of the NDT contractor's scope.

Records the operator and regulator expect

Section 192.807 is precise about OQ records. For each qualified individual the operator must be able to show the identity of the individual, the covered tasks the individual is qualified to perform, the dates of current qualification, and the qualification methods used. Records must be kept while the individual is performing the covered task and for five years after the individual stops performing it. Part 195 contains a parallel recordkeeping requirement for liquid operators.

In audits, the practical failures are rarely missing paper. They are mismatches. The task name on the evaluation record does not match the operator's covered task list. The re-evaluation interval has lapsed because the contractor tracked dates differently from the operator. The qualification method listed is work history alone. A non-qualified helper performed a task without a record of who directed and observed the work. Or the program says it follows B31Q span-of-control limits but the crew ratios on the day did not.

For NDT, the parallel record set is the employer's written practice, each technician's certification record with training hours, experience, examination results and vision examinations, and the procedure and calibration records for the job. When both record sets reference the same person and task, an auditor can follow the chain from the evaluation to the reading. When they are kept in different systems by different parties, the chain breaks, and that is where most findings come from.

Common mistakes with B31Q and OQ

• Treating B31Q as the law. It is voluntary in the USA. The four-part test in Subpart N or Subpart G is the legal requirement.
• Using the B31Q task list as a closed list. PHMSA guidance is clear that absence from an industry list does not remove a task that meets the four-part test.
• Assuming NDT certification equals OQ. An ASNT certificate shows method competence; it does not show the operator has evaluated the individual on its covered task and abnormal operating conditions.
• Assuming OQ equals NDT certification. An OQ card for a measurement task does not satisfy a contract or code that calls for SNT-TC-1A or CP-189 certified personnel.
• Relying on an off-the-shelf program without mapping it. PHMSA guidance notes that buying a third-party OQ program does not relieve the operator of its own duty to identify covered tasks and qualify people for them.
• Ignoring abnormal operating conditions. The definition of qualified includes recognising and reacting to them. Evaluations that test only the steps of the task miss half the requirement.
• Letting re-evaluation intervals drift. Section 192.805 requires the operator to set intervals; it does not set them for you, so the program must say what they are and the records must show they were met.

Regulatory overlay: states, liquids and Canada

In the USA, PHMSA shares enforcement of the pipeline safety regulations with state agencies under certification agreements, and many intrastate pipelines are inspected by a state commission rather than PHMSA directly. State programs enforce the same OQ rule and can adopt additional requirements for intrastate facilities, so confirm with your state pipeline safety program whether anything is added. Hazardous liquid operators follow Part 195 Subpart G, which uses the same four-part test, and API RP 1161 is the industry guidance document frequently used alongside it.

Canada has no direct equivalent of Subpart N. Federally regulated pipelines fall under the Canada Energy Regulator, whose Onshore Pipeline Regulations require companies to run training programs for employees directly involved in operating the pipeline and to manage contractor competence within their management systems. CSA Z662, Oil and gas pipeline systems, is referenced by federal and provincial regulators and expects operators to verify that people working on or for the system are trained and competent. Provincially regulated pipelines answer to their own regulator, such as the Alberta Energy Regulator. Some Canadian operators use B31Q voluntarily as a framework, because it was written for any operator regardless of size. As in the USA, NDT personnel are certified separately; in Canada that is often CGSB/NRCan certification to CAN/CGSB-48.9712 (ISO 9712), and some operators also accept ASNT-based certification. Confirm the requirement with the operator and the regulator for the specific line.

How Atlantis supports this

Atlantis provides pipeline NDE, including UT thickness and corrosion mapping, MT, PT, visual examination, radiography through crews licensed where the work is, and guided-wave screening, performed by technicians certified under an ASNT SNT-TC-1A written practice with ASNT Level III oversight of procedures. We do not provide OQ evaluations, B31Q programs or OQ training. On operating pipelines we work inside the operator's OQ program: we supply certification, training and procedure records so the operator, or its chosen evaluation provider, can confirm qualification for the covered tasks it has identified. Results go to the operator's integrity team, which makes the engineering decisions. See pipeline inspection services or ask for a scope and quote; we reply within 24 hours.

If your question is about building NDT competence rather than OQ, the complementary path is ASNT certification: see ASNT certification pathways, NDT Level II training and ASNT Level III training, or our written practice development support for contractors who need an SNT-TC-1A program operators will accept.

Frequently asked questions

What is ASME B31Q pipeline personnel qualification?

ASME B31Q is a consensus standard that sets out how to identify covered tasks affecting pipeline safety or integrity, qualify individuals to perform them, and manage those qualifications. The current edition listed by ASME is 2025. It is used to design operator qualification programs for both liquid and gas pipelines.

Is ASME B31Q mandatory?

Not under US federal rules. PHMSA guidance describes B31Q as non-mandatory because it has not been incorporated by reference into 49 CFR Parts 192 or 195. It becomes binding on an operator only to the extent the operator's written program adopts it.

What is the difference between B31Q and the OQ rule?

The OQ rule, 49 CFR 192 Subpart N and 195 Subpart G, is the legal requirement and is built around a four-part covered task test. B31Q is a voluntary standard that offers a covered task list and more detailed expectations for evaluation, training, span of control, records and program effectiveness, and can extend into new construction.

What is the four-part test for a covered task?

An activity is a covered task if it is performed on a pipeline facility, is an operations or maintenance task, is performed as a requirement of Part 192 or 195, and affects the operation or integrity of the pipeline. All four conditions must be met, and the operator must identify its own covered tasks.

Can the ASME B31Q covered task list replace our own task list?

No. PHMSA guidance says an industry list such as B31Q or API RP 1161 is a useful starting point, but a task missing from that list is still a covered task if it meets the four-part test. Map your activities against the test, not just the list.

Is NDT a covered task under operator qualification?

It depends on the activity and the operator's program. Construction weld NDT is generally governed by construction requirements such as 192.243 rather than OQ. On an operating pipeline, inspection and measurement tasks required by the regulations that affect integrity are often identified as covered tasks by the operator.

Does an ASNT Level II certificate count as OQ qualification?

Not by itself. ASNT certification shows method competence under the employer's written practice. OQ requires the operator's documented evaluation for the specific covered task, including recognising and reacting to abnormal operating conditions. Many operators use the certificate as a prerequisite within the OQ evaluation.

How long must OQ records be kept?

Under 192.807, records must be kept while the individual performs the covered task and for five years after the individual stops performing it. They must identify the individual, the covered tasks, the dates of current qualification and the qualification methods.

Can someone who is not qualified perform a covered task?

Yes, but only if directed and observed by an individual who is qualified, as provided in 192.805. The operator's program sets how many non-qualified individuals one qualified person may direct and observe.

Can work history alone be used to qualify someone?

No, not for current qualifications. Section 192.809 allowed work performance history review as the sole method only for people performing a covered task before October 26, 1999, and that allowance ended after October 28, 2002. Since December 16, 2004, on-the-job observation alone is also not accepted.

Does Canada use ASME B31Q?

Some Canadian operators use B31Q voluntarily, but Canada has no direct equivalent of Subpart N. Federally regulated pipelines follow the Canada Energy Regulator's Onshore Pipeline Regulations and operators reference CSA Z662 for competence. Confirm requirements with the applicable regulator.

Need certified NDE crews who can slot into your OQ program? Send us the scope and your covered task list. For related reading, see the ASME B31.8 gas pipeline code guide, the ASME B31.4 liquid pipeline code guide and where API 570 stops and B31.4/B31.8 start. Or simply ask our Level III a question.

Sources: ASME B31Q product page; 49 CFR 192.801, 192.803, 192.805, 192.807, 192.809, 192.243 and 195.501; PHMSA Operator Qualification Enforcement Guidance. Confirm against the current edition of B31Q and current regulations.