Should operators develop OQ program provisions in anticipation of future industry mergers and acquisitions?
While industry consolidation by mergers and acquisitions is a current fact of life, an operator need not anticipate how its programs might change if it is involved in such consolidations. However, specific provisions for addressing OQ requirements following mergers or acquisitions should be developed and documented as soon as practical after such business transactions have been negotiated (e.g., provisions for either combining the programs or maintaining distinct programs, so long as compatibility issues are reviewed and resolved).
