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The Top 5 Takeaways from Contagious Compliance: How New York’s OQ Rule Is Spreading

Top 5 Takeaways from Contagious Compliance Webinar
June 18, 2026
Chris Taylor, ITS Vice President of Learning and Product, hosted Adam Day, Director of Training and Qualification Services at the Northeast Gas Association (NGA), for the latest episode of Regulation Navigation — ITS’s quarterly webinar on pipeline industry news and trends. Adam shared an inside look at New York’s expanded OQ rule, how it’s already reshaping compliance programs across the Northeast, and where the rest of the country should be paying attention.
The conversation covered the following 5 key takeaways about how New York’s OQ rule is spreading — and what it means for your program:
  1. Know What New York’s OQ Rule Actually Requires New York’s OQ rule has been in effect for over three years, and its requirements go significantly beyond the federal baseline. The rule expands covered task and qualified individual definitions, mandates leader-led training with a required 48-hour separation between training and qualification evaluations, and converts to a 2-part covered task definition — meaning any task performed on a pipeline facility that affects operation or integrity is covered.
  2. State-Specific OQ Is Catching On The Northeast is diverging from the federal PHMSA baseline — and the gap is widening. Connecticut, Massachusetts, and New Jersey are each layering on supervisor qualification requirements, leader-led training mandates, credentialed trainers and evaluators, and program ownership requirements that go beyond 192 Subpart N.
  3. The Change Most Likely to Spread: Supervisor and Inspector Competency Of all the elements in New York’s rule, Adam identified supervisor and inspector competency as the one other states are most likely to adopt next. Connecticut, New Jersey, and Massachusetts have all already included supervisor qualification requirements that New York itself doesn’t have.
  4. Span of Control Is Being Abused — and Regulators Have Noticed Span of control was designed to support on-the-job training, not to paper over qualification or staffing gaps. Programs that lean on it as a substitute for having qualified personnel in the field should expect scrutiny.
  5. Don’t Let Your Program Drift OQ Drift — the gradual divergence of your program from current regulations and best practices — is one of the most common and most preventable compliance risks. Participate in industry association OQ collaborations and standards committees.

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