Every obligation your gas system carries, on one calendar, before the inspector asks.
Operator Qualification programs, safety plans, and recordkeeping for municipal and small natural-gas distribution systems under 49 CFR Parts 191, 192 and 199 and OAC 165:20.
Built in Cushing, Oklahoma, for Oklahoma systems first.
What the OCC inspector will ask to see
An audit is a document request. Most findings against small systems are not about pipe; they are about a record that was not kept, a review that was not dated, or a qualification that quietly expired.
- OQ programWritten plan, covered-task list, evaluation methods, and who is qualified for what, as of today §192.805
- O&M manualCurrent procedures, annual review evidence, and proof staff were trained on them §192.605
- Emergency planPlan, liaison with fire and police, and the annual review §192.615
- Public awarenessProgram, mailing records, and the effectiveness evaluation §192.616
- Drug & alcoholAnti-drug and alcohol misuse plans, random-pool records, contractor coverage Part 199
- DIMPWritten integrity plan, threat ranking, and the measures you said you would take Subpart P
- Leak recordsSurvey dates, grades, repair timelines, and re-checks §192.723, OAC 165:20
- CorrosionCP reads within the 15-month window, rectifier checks, atmospheric inspections Subpart I
- Damage preventionLocate tickets, responses, and any excavation-damage reports §192.614
- Annual reportForm 7100.1-1 filed and matching your own mileage and service counts §191.11
Operator Qualification, kept current instead of rebuilt before each audit
Subpart N does not care how good your crew is. It cares whether you can show, for each covered task, who is qualified, how they were evaluated, and when that lapses.
Written OQ program
A plan that fits a small system: the covered tasks you actually perform, evaluation methods that match them, and requalification intervals you can keep.
Covered-task list
Built from your O&M manual, not a generic list. If you don't do it, it isn't on the list; if you do, it has an abnormal-operating-conditions component.
Evaluations and records
Written, performance, and on-the-job evaluations with dated evaluator records that stand up to a request. Evaluator independence handled per your program.
Contractor designation
When contract crews perform covered tasks on your system, you accept their qualifications and designate the named people, per task, with a record you can revoke. Responsibility stays with the operator of record.
Requalification calendar
Every qualification has a lapse date. You see them 90, 60 and 30 days out, by person and by task, so nobody is on a job the day after they aged out.
Program review
Periodic review of the program itself, recorded, so the inspector's "when was this last updated?" has a date on it.
Safety programs that stay written, dated and reviewed
Most small systems have these plans somewhere. What they usually lack is the annual review, the training record, and a person whose job it is to remember.
O&M manual §192.605
Procedures matched to your system, reviewed annually, with training sign-offs tied to each revision.
Emergency plan §192.615
Gas emergency response, mutual-aid contacts, fire and police liaison, and the documented annual review and drill.
Public awareness §192.616
Baseline program under API RP 1162, mailing and outreach records, and the effectiveness evaluation on the four-year cycle.
Drug & alcohol Part 199
Anti-drug and alcohol misuse plans, consortium enrollment for random testing, contractor coverage, and MIS reporting when you are selected.
Distribution integrity Subpart P
A DIMP plan sized to a small system: threats you actually have, ranked, with measures you can fund, and the annual and five-year reviews on the calendar.
Damage prevention §192.614
OKIE811 tickets routed to the right person, responses timed and logged, and excavation damage reported the way the OCC expects.
How it works
Compliance review
We go through your system, your plans and your records against 49 CFR 192, 199 and OAC 165:20 and give you a written list: what's in place, what's missing, what's expired.
Build the calendar
Every recurring obligation your system carries goes on one calendar with its interval, its owner, and the record that proves it was done.
Run it together
You perform the work and keep the authority. We keep the calendar, chase the dates, hold the records, and get you ready when the inspector schedules.
You stay the operator of record. We make that easier, not blurrier.
The operator files and attests. Nothing is submitted to PHMSA or the OCC in your name without your review and signature.
Your records are yours. Exportable at any time, and delivered back to you in a closing binder if we ever part ways.
Field crews are your crews. Whether they are city staff or a designated contractor, qualification and responsibility stay with the operator.
Request a compliance review
Tell us about your system and we'll come back within two business days with what a review would cover and cost.
Or email support@thecompliancehq.com. Phone: [number].