Every person, every qualification, current.
An inspector does not ask whether your crew is good. They ask who was qualified for what, on what date, and how you know. We keep that answer ready for every person: task qualifications, licences, training, drug and alcohol program records, and onboarding files.
What the inspector will ask to see
- Who is qualified for which covered task, and until whenWho is qualified, for which covered tasks, the dates and the methods; prior records kept 5 years. 49 CFR 192.807
- Training records with dates and sign-insOklahoma public employers record the date, location, course, trainer and attendees. OAC 380:40-1-22(d)
- Licences and continuing-education hours for certified operatorsOklahoma renews every year by June 30; Indiana every three years with continuing education. OAC 252:710; IC 13-18-11-6.5
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. We track each one and warn you well ahead of it, 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.
The rest of the file
Drug & alcohol Part 199
Anti-drug and alcohol misuse plans, consortium enrollment for random testing, contractor coverage, and MIS reporting when you are selected.
Onboarding files: new hires start with the records their role requires, collected and checked before their first covered task, and the file stays complete while they work for you.
Before a first safety-sensitive task: the past 2 years of DOT drug and alcohol history from previous employers, and a full Clearinghouse query for CDL drivers. 49 CFR 40.25, 382.701
Operator licences and continuing education: we track renewal dates and education hours for every operator and warn you well ahead of a lapse.
Oklahoma: 4 to 16 hours a year by class, 4 of them classroom. Indiana: contact hours per three-year period, at least 70% technical. OAC 252:710; 327 IAC 8-12-7.5, 5-23
Safety training: recurring training on a calendar, with sign-in records kept.
Oklahoma public employers train all employees no less than quarterly. OAC 380:40-1-22
Drivers: drug and alcohol testing and Clearinghouse records for your CDL drivers, and qualification files wherever your state applies them. We check which rules reach your fleet.
A city's CDL drivers are covered by federal drug and alcohol testing and Clearinghouse rules, even though the federal motor carrier rules otherwise exclude government transportation. 49 CFR 382.103(c), 390.3T(f)(2)
What's coming
- November 20, 2026Hazard communication update: employers update labels, the written program and training as needed. 29 CFR 1910.1200(j)(2)(ii)
How it works
Inventory
We list every person, every role and every qualification that role needs.
Collect and check
We gather the records, check them against the requirement, and flag what is missing or about to lapse.
Keep it current
Lapse dates go on the calendar. We follow up before they pass, and the file is ready when someone asks.
Papers
- WP-P1One person, three kinds of qualification. In preparation.
Paper in preparation.
- WP-P2Drug & alcohol for a two-person system
Version 1.0, 25 September 2026.
Tell us about your system.
You stay the operator of record, and your people stay yours. We run the program and the records, and bring in qualified experts under contract when the work needs them.