The Pipeline and Hazardous Materials Safety Administration posted Public Awareness Program frequently asked questions on the PHMSA Stakeholder Communications web site, http://primis.phmsa.dot.gov/comm/PublicEducation.htm.
Several questions have been raised about question 4: When must an operator complete the initial distribution of RP 1162-compliant communications to stakeholders? According to PHMSA, the answer depends on the RP 1162 frequency for communicating with the audience.
A “base date” of June 20, 2006, applies to all operator types and audiences. The initial distribution of awareness materials must be completed by the “base date” plus the RP 1162 frequency.
For example, gas distribution operators must deliver awareness materials to customers by Dec. 20, 2006. All operator types must deliver awareness materials to local public officials by June 20, 2009. (This does not reflect the supplemental delivery frequency for transmission operators located in high consequence areas [HCAs]. RP 1162 states that operators with facilities located in HCAs must make annual contact with public officials at a minimum, or more often as appropriate.)
Public Awareness Programs must be completed by the “base date” of June 20, 2006. There is no requirement for awareness materials to be delivered by the “base date.” The due date for delivery of awareness materials to stakeholders is calculated by a simple formula – “base date” plus the frequency specified in RP 1162.
Many people have noticed that the answer differs from what PHMSA presented at the workshops. At the workshops, PHMSA stated that “Initial distribution of awareness materials must be completed by June 20, 2007.” Based on feedback from industry after the workshops, PHMSA determined that a single date for completion is not appropriate. Hence the new FAQ.
PHMSA expects to issue an Advisory Bulletin in April 2006 that will provide detailed instructions for operators to submit written programs.