In This Issue

PHMSA Pipeline Safety: Information Collection of API RP 1173 for Gas Distribution Systems

[Docket No. PHMSA–2022–0060]

The PIPES Act contains a provision for PHMSA to prepare a report for Congress on the status of the implementation of safety management systems in the gas distribution industry. PHMSA is proposing to conduct a one-time information request of gas distribution operators whether they are implementing safety management systems. PHMSA is requesting comments on their proposed survey format and questions. Comments are to be submitted by November 7, 2022, to the E-Gov Website at and include the docket number, PHMSA–2022–0060. The information request will be finalized in 2023 and conducted to meet the December 2023 deadline for the report to Congress.

PHPMSA is proposing that the information request would be submitted through the PHMSA Portal in a manner similar to submitting other reports. The information request is based on the ten-element format of the API Recommended Practice 1173. PHMSA recognizes that gas distribution operators may have safety management systems that are different or are based on other standards. In those cases, PHMSA asks that the gas distribution operator to respond as best fits their safety management program elements.

The bulk of the information request questions are fill in the blank by the operator or are a selection from a picklist. There are some spots for explanation of responses, but they are currently expected to be limited to 100 characters.

The information request asks if the gas distribution operator is or is not implementing a safety management system and if not, why they are not. PHMSA is interested in knowing how the operator became aware of pipeline safety management systems, in particular API RP 1173. If the operator is in the process of implementation, PHMSA would like to know the status of the implementation and when full implementation is expected. PHMSA is interested in how much time and money has been spent by safety management system element in the implementation effort and which of the elements was most difficult to implement. For implemented systems, PHMSA is also asking if the safety management system has been evaluated and, if so, by whom.

RCP has been involved in the development and implementation of pipeline safety management systems as well as evaluating the performance and maturity of safety management systems for its clients. If your organization is just starting to think about implementation or is at some point in your implementation, RCP has the experts that can assist you. If your organization would like to have a third-party evaluation of your safety management system, RCP has the auditors and assessors that perform those evaluations. For additional information please contact Jessica Foley.