In our July 2004 newsletter, we mentioned that OPS is proposing to incorporate API RP 1162 into the gas and hazardous liquid pipeline regulations. Our Vice President of Project Development, Susan Waller, served on the API committee that developed RP 1162. She would like to add the following comments:
“There is no doubt that everyone in our industry agrees that communication is an important element in helping to assure the safety of our nation’s energy transportation pipeline infrastructure. In addition, it is important for us to recognize that long before RP 1162 was developed, pipeline operators have been communicating with affected stakeholders.
RP 1162 provides operators with a formal process to take credit for and improve their ongoing pipeline awareness communication efforts. Pipeline specific communication takes place routinely during operators’ maintenance programs, emergency responder training, excavator meetings, One-call alliances, incremental pipeline / facilities expansion activities, and day-to-day field personnel interactions with those living and working along the rights-of-way.
What is new for most operators is formalizing their public education programs, documenting targeted communications and evaluating their program’s effectiveness. RP1162 provides operators with a structured and documented process approach that recognizes measurable, ongoing program improvements. If operators plan well, they can minimize their costs and maximize their program’s effectiveness.”
Overview
The new rule will set minimum requirements for pipeline operators to develop, implement, and manage public education programs. This will include requirements regarding the stakeholder audiences that pipeline operators should communicate information to, the content of the messages and information they should communicate, and the frequency by which they should communicate with particular audiences. It will also address management of the operators’ programs, including evaluating their programs for effectiveness.
OPS proposes to incorporate RP 1162 by reference into the new rule. OPS worked with industry representatives, state pipeline partners and the National Association of Pipeline Safety Representatives (NAPSR) in developing the new rule. Baseline and supplemental program requirements for different pipeline operator types are summarized in a set of tables in API RP 1162 that may be found at http://primis.rspa.dot.gov/edu/RP1162/Sect-2_Tables_Prelim_Post-to-Web_090903.pdf. If an operator’s current public education program does not comply with API RP 1162, the operator would be required to modify the program to come into compliance. Information on API RP 1162, may be found at: http://primis.rspa.dot.gov/edu/rp1162.htm
Procedural Update – 12/14/04 Public Meeting
OPS will be holding a public meeting on “Communicating with the Public” from 1:00 p.m. to 5:00 p.m. on Tuesday, December 14, 2004 at the Marriot Washington, 1221 22nd Street, NW, Washington, D.C. At the public meeting, OPS will discuss its analysis of comments received in response to the Notice of Proposed Rulemaking (NPRM). Numerous comments to the NPRM raised questions relating to the regulator’s use of language in consensus standards that employ the words “should” and “shall.” OPS will also discuss and solicit comments on its plans to meet statutory responsibility to review communications programs of pipeline operators. The United States Senate Appropriations Committee has proposed a budget increase to fund a central review clearinghouse, but that model is contingent on availability of financial resources. Other models for review of communications plans will also be discussed at the public meeting.
If you would like information regarding RCP’s Public Awareness Program development, e-mail Laura Wager at lwager@your-rcp.com or call (713) 655-8080.