Two workshops on Public Awareness for pipeline operators held recently by PHMSA will help ensure operators’ full compliance with the new public awareness program requirements included in API RP 1162. Presentations can be found at http://primis.phmsa.dot.gov/comm/PublicAwarenessWorkshops.htm.
PHMSA believes RP 1162 sharpens the focus for operators to invest in effective communications that include messages that are received and understood by the audience, and that the awareness will lead to behavioral changes. PHMSA representatives noted that the program offers an opportunity for operators to create effective programs as well as spotlighting the need for individual operators to take ownership of awareness programs. PHMSA stressed the importance of creativity in yielding effective and efficient programs that make a difference in pipeline awareness and safety. Following is a recap of clarifications made during the meetings.
Written programs must be completed by June 20, 2006. A one-year extension from this date applies to both propane systems and master meter operators having less than 25 customers. Initial distribution of awareness materials must be completed by June 20, 2007. (This is a new requirement.) Operators’ first evaluation of program effectiveness must be completed by June 20, 2010. A one-year extension from this date applies to both propane systems and master meter operators having less than 25 customers.
Programs must follow the general program recommendations, including baseline and supplemental requirements of RP1162, unless written program justification includes why compliance with the RP is not practicable and not necessary for safety.
Stakeholder Audience Clarification
Operators are not required to address the general public as an audience. RP 1162 identifies the affected public audience, which includes:
- residents located along the distribution system and adjacent to the transmission pipeline and gathering pipeline right-of-way
- customers of LDCs and transmission operators
- places of congregation
- residents near storage or other major operational facilities.
For detailed definitions, refer to RP 1162’s section 3.1.
PHMSA pointed to RP 1162’s sections 2.4.6 and 8.4.2 regarding cooperative information exchange or shared public awareness activities. They indicated that while collaboration adds value and leverage to awareness campaigns, operators also should be able to produce documentation that demonstrates operator-specific results. In addition, PHMSA understood that collaborative efforts create challenges for operators to partner for success and that operators may consider nontraditional partners such as One-call Centers and schools along the right-of-way.
PHMSA indicated that operators’ written public awareness programs must describe the process operators use to determine whether supplemental enhancements are warranted. In addition, operators must document when and where along its pipeline a more intensive public awareness effort is needed. These pipeline right-of-way areas include high consequences areas; land development activity; third-party damage incidents; and a pipeline’s incident history. Forms of supplemental enhancements include increased frequency of communications; enhanced message content and additional delivery method and/or media; and/or widening the stakeholder audience coverage area beyond the baseline program. Implementation records must document areas along the pipeline route when supplemental elements have been implemented. Refer to RP 1162’s section 6.
Integrity Management Communication Requirements – ASME B31.8S and RP 1162
PHMSA stated that some differences are included in the two rules but operators may develop and implement a single external communication program to address the requirements of both rules. Operators must be able to demonstrate when and how their programs adequately address the requirements of each.