NTSB Safety Recommendation P-90-021

NTSB safety recommendation P-90-021.

THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: ASSESS EXISTING GAS INDUSTRY PROGRAMS FOR EDUCATING THE PUBLIC ON THE DANGERS OF GAS LEAKS AND ON REPORTING GAS LEAKS TO DETERMINE THE APPROPRIATENESS OF INFORMATION PROVIDED, THE EFFECTIVENESS OF EDUCATIONAL TECHNIQUES USED, AND THOSE TECHNIQUES USED IN OTHER PUBLIC EDUCATION PROGRAMS AND BASED ON ITS FINDINGS, AMEND THE PUBLIC EDUCATION PROVISIONS OF THE FEDERAL REGULATIONS.

Priority: CLASS III

Overall Status: Closed - Acceptable Action

Issued Date: 1990-04-20

Adopted Date: 1990-03-27

Overall Date Closed: 2003-11-21

Synopsis: IN A 7-MONTH PERIOD BEGINNING SEPTEMBER 16, 1988, THE NATIONAL TRANSPORTATION SAFETY BOARD INVESTIGATED 5 NATURAL GAS ACCIDENTS IN THE KANSAS CITY-TOPEKA AREA THAT INVOLVED THE GAS DISTRIBUTION SYSTEMS OWNED BY KANSAS POWER AND LIGHT COMPANY (KPL). CORROSION DAMAGE WAS INVOLVED ON EACH OF THE 3 GAS SERVICE LINES AND THE 2 CAST IRON GAS MAINS. EACH OF THE GAS LINES INVOLVED WERE INSTALLED BEFORE THE FEDERAL MINIMUM GAS PIPELINE SAFETY REGULATIONS BECAME EFFECTIVE AND THE FAILURES ON THE GAS SERVICE LINES INVOLVED CUSTOMER-OWNED PIPE THAT HAD NOT BEEN PROTECTED AGAINST CORROSION DAMAGE. THESE ACCIDENTS KILLED 4 PEOPLE, INJURED 12 OTHERS AND DESTROYED 4 HOUSES.

Probable Cause: None

Keywords: Training and Education, Public Education (Pipeline)

Ntsbnumber: DCA89MP014

Report Number: PAR-90-03

Addressee Name: RSPA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2003-11-21

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1995-02-07

Communication Type: Recommendation Reiteration

Communication Contents: As a result of its investigation of a natural gas explosion and fire in Edison, New Jersey, on March 23, 1994, the Safety Board reiterated Safety Recommendation P-90-21 to RSPA on February 7, 1995. The Board found that the Edison accident illustrated the need for RSPA to take an active role in ensuring that pipeline operator public education programs effectively provide the information the public needs to recognize the location of pipelines, recognize potential hazards, report a pipeline emergency condition, and safely evacuate an area.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1997-10-31

Communication Type: Official Correspondence

Communication Contents: NTSB REQUESTED A FOLLOWUP ON THIS DATE 10/31/97.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-04-18

Communication Type: Official Correspondence

Communication Contents: The Safety Board understands that RSPA, on February 13, 2001, held a public meeting to cover how the public can gain improved access to information about how pipelines are being operated and how pipeline risks can be controlled. Further, the Board notes that RSPA is actively encouraging the industry to improve public education about pipeline safety, especially through its damage prevention efforts. RSPA is working with the pipeline industry to assess public education efforts beyond those dealing with damage prevention to underground facilities, is evaluating industry approaches to use in educating the public by working with the American Petroleum Institute and other pipeline industry trade associations, and is also considering a survey of pipeline companies to review and evaluate the effectiveness of their public education programs in enhancing pipeline safety in local communities. Given the 10-year timeframe since its issuance and the lack of positive action by RSPA, Safety Recommendation P-90-21 remains classified "Open--Unacceptable Response."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1993-03-08

Communication Type: Official Correspondence

Communication Contents: IN THE JANUARY 5, 1993, BOARD MEETING FOR THE SUMMARY REPORT ON THE PIPELINE OVERPRESSURE OF PEOPLES GAS LIGHT AND COKE COMPANY LOW-PRESSURE DISTRIBUTION SYSTEM SERVING THE RIVER WEST AREA OF CHICAGO, ILLINOIS, ON JANUARY 17, 1992, THE BOARD RECLASSIFIED RECOMMENDATION P-90-21 AS "OPEN--ACCEPTABLE ALTERNATE RESPONSE."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-06-29

Communication Type: Official Correspondence

Communication Contents: THE SAFETY BOARD ASKED THAT RSPA ASSESS EXISTING GAS INDUSTRY PROGRAMS FOR EDUCATING THE PUBLIC ON THE DANGERS OF GAS LEAKS AND ON REPORTING GAS LEAKS TO DETERMINE THE APPROPRIATENESS OF INFORMATION PROVIDED, THE EFFECTIVENESS OF EDUCATIONAL TECHNIQUES USED, AND THOSE TECHNIQUES USED IN OTHER PUBLIC EDUCATION PROGRAMS AND THAT RSPA, BASED ON ITS FINDINGS, AMEND THE PUBLIC EDUCATION PROVISIONS OF THE FEDERAL REGULATIONS. THE BOARD IS DISAPPOINTED THAT RSPA HAS NOT IMPLEMENTED THE RECOMMENDED ACTION. ALSO, RSPA HAS NOT ADDRESSED THE SPECIFIC ISSUE OF ASSESSING EXISTING GAS INDUSTRY PROGRAMS FOR PUBLIC EDUCATION ON GAS LEAKS. ACCORDINGLY, P-90-21 HAS BEEN CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE," PENDING A FURTHER REPLY FROM RSPA ON HOW IT INTENDS TO IMPLEMENT THE RECOMMENDATION.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2000-07-13

Communication Type: Official Correspondence

Communication Contents: ON 6/29/99, BASED ON INFORMATION IN THE RSPA LETTER OF 10/30/98, P-90-21 WAS CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE," PENDING A FURTHER RESPONSE FROM RSPA. COPIES OF RECOMMENDATIONS P-87-34, P-90-21, P-95-4, P-96-1, P-97-6, P-97-7, P-97-8, P-98-1, P-98-2, P-98-3, P-98-4, P-98-5, AND P-98-25 AND ASSOCIATED CORRESPONDENCE ARE ENCLOSED. THE SAFETY BOARD WOULD APPRECIATE LEARNING OF ANY ACTION TAKEN OR PLANNED TO COMPLY WITH THESE RECOMMENDATIONS, ESPECIALLY P-97-7 AND -8, WHICH MAY BE DISCUSSED AT A BOARD MEETING.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-11-21

Communication Type: Official Correspondence

Communication Contents: The Safety Board is aware that RSPA has been working closely with its stakeholders to satisfy the Board's recommendations. We appreciate receiving a copy of Recommended Practice (RP) 1162 "Public Awareness Programs for Pipeline Operators," developed by the American Petroleum Institute in conjunction with RSPA's Office of Pipeline Safety (OPS). The Board was particularly pleased to note that organizations representing essentially the entire gas and hazardous liquid pipeline industry issued a joint statement on May 28, 2003, noting that they are "committed to adopting a consensus standard establishing a baseline public awareness program for pipeline operators" in 2003. We note further that they urged RSPA and the OPS to incorporate RP 1162 into the pipeline safety regulations, and they also committed to working with RSPA/OPS to reach out to pipeline operators to assist them in aligning their current public information programs with the standard. We also note that the OPS has held pipeline operator workshops to help pipeline operators understand the RP 1162 and is committed to incorporating by reference RP 1162 into the pipeline safety regulations (49 CFR Parts 192 and 195). In view of the extensive initiatives to address the Board's recommendations, Safety Recommendations P-90-21, P-98-37, and -38 are classified "Closed--Acceptable Action." We commend RSPA and its stakeholders on these communications and public education initiatives and for helping localities, States, and industry to improve their public awareness programs.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-02-27

Communication Type: Official Correspondence

Communication Contents: The Safety Board appreciates the comprehensive update on the activities related to the development of Recommended Practice (RP) 1162, Public Awareness Programs for Pipeline Operators. We also appreciate the meeting you held for Board staff with the American Petroleum Institute's standards team on the development of this new RP. The Safety Board notes the other ongoing communications and public education initiatives, including the development of an online resource for pipeline materials and information, "Pipeline 101," and a collaborative project with the National Association of State Fire Marshals to prepare first responders to better respond to pipeline emergencies and to enlist their help in damage prevention and education of state and local officials about pipelines. We further note that RSPA has contracted with the National Academy of Sciences-Transportation Research Board to conduct a study of options to prevent encroachment on pipelines. RSPA has also hired five full-time Community Assistance and Technical Services (CATS) inspectors to help states and industry improve their public awareness programs. The Safety Board commends RSPA for its extensive efforts to provide pipeline operators with guidance on how to improve public aware programs. As Safety Recommendations P-90-21, P-98-37, and P-98-38 call for revisions to the pipeline safety regulations, incorporation of RP 1162 into the regulations by reference will satisfy these recommendations. Pending issuance of that final rule, P-90-21, P-98-37, and P-98-38 remain classified "Open--Acceptable Response."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1993-01-26

Communication Type: Official Correspondence

Communication Contents: PENDING COMPLETING OF THE ADVISORY BULLETIN AND REVIEW BY THE SAFETY BOARD, SAFETY RECOMMENDATION P-90-21 WILL BE CLASSIFIED AS "OPEN--ACCEPTABLE ALTERNATE RESPONSE."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1994-04-22

Communication Type: Official Correspondence

Communication Contents: THE BOARD AND RSPA STAFF DISCUSSED THIS RECOMMENDATION ON OCTOBER 29, 1992. DURING THAT MEETING, BOARD STAFF NOTED THAT GAS-INDUSTRY PUBLIC EDUCATION PROGRAMS APPEAR TO RECEIVE LESS THAN HALF AS MUCH PUBLIC RECOGNITION AS OTHER PUBLIC EDUCATION PROGRAMS, SUCH AS THOSE THAT PROMOTE THE USE OF SEATBELTS AND CHILD RESTRAINTS. BOARD PERSONNEL EXPLAINED THAT RSPA NEED TO IDENTIFY THE TECHNIQUES THAT MAKE OTHER PUBLIC EDUCATION PROGRAMS MORE EFFECTIVE, DETERMINE WHICH OF THEM WOULD IMPROVE GAS-INDUSTRY PROGRAMS, AND INCORPORATE THEM INTO THE FEDERAL REQUIREMENTS. ON APRIL 5, 1993, THE OPS ISSUED ADVISORY BULLETIN ADB-93-02, WHICH DIRECTED "GAS PIPELINE FACILITY OWNERS AND OPERATORS TO REVIEW AND ASSESS THEIR CONTINUING EDUCATION PROGRAMS AS APPLIED TO CUSTOMERS AND THE PUBLIC." THAT BULLETIN INCLUDED PERTINENT INFO ON THE ACCIDENTS INVESTIGATED BY THE BOARD, AND IN PART IT CITED P-90-21. IT ADVISED ALL NATURAL GAS OWENERS AND OPERATIONS TO REVIEW AND ASSESS THEIR CONTINUING EDUCATION PROGRAMS TO "ASSURE THAT THEY ARE IN COMPLIANCE WITH THE PROVISION OF 49 CFR 192-615(D)." ALTHOUGH THE BULLETIN PROBABLY PROMPTED MOST OPERATORS TO REVIEW THEIR PROGRAMS, THE BOARD DOES NOT REGARD IT AS RESPONSIVE TO P-90-21 OR CONSISTENT WITH THE DISCUSSIONS ON OCTOBER 29, 1992, BETWEEN RSPA AND BOARD STAFF. THE BOARD ENCOURGES RSPA TO PERFORM THE EVALUATIONS NECESSARY TO ACCOMPLISH THE RECOMMENDED ACTION AND HAS CLASSIFIED P-90-21 "OPEN--UNACCEPTABLE RESPONSE."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1994-02-22

Communication Type: Official Correspondence

Communication Contents: -From Carl W. Vogt, Chairman: The National Transportation Safety Board has reviewed the actions taken by the Research and Special Programs Administration's (RSPA's) Office of Pipeline Safety (OPS) in response to Safety Recommendations P-78-24, P-84-26, P-87-9 and -21, and P-90-21. Safety Recommendations P-78-24 asked RSPA to amend 49 CFR 192.181(a) to specifically define the requirement for location and number of emergency valves. In response to this recommendation, the Associate Administrator for Pipeline Safety issued Advisory Bulletin 94-02 on January 13, 1994. That bulletin provided operators of gas distribution systems with the OPS criteria for selecting emergency valve locations in high-pressure distribution systems. The Safety Board has reviewed those criteria and has determined that their use by OPS and State personnel in compliance assessments will achieve the intended objective. Therefore, Safety Recommendation P-78-24 is classified "Closed--Acceptable Alternate Action." Safety Recommendation P-84-26 asked RSPA to amend Federal regulations governing the pipelines that transport highly volatile liquids (49 CFR Part 195) to require a level of safety for the public comparable to that now required for natural gas pipelines (49 CFR Part 192). The Safety Board considered natural gas pipeline safety requirements superior to those for liquid pipelines. On February 4, 1994, the OPS issued a Final Rule, “Operation and Maintenance Procedures for Pipelines,” which requires that operation and maintenance procedures for both natural gas and liquid pipelines be more consistent. Although the action partially satisfies the objective of Safety Recommendation P-84-26, similar measures are needed in many other areas, such as establishing criteria for the performance of systems used to monitor the operation of pipelines. We encourage your continuing efforts on this issue and will maintain Safety Recommendation P-84-26 in an "Open—Acceptable Response” status. Safety Recommendation P-87-9 asked RSPA to amend 49 CFR Part 192 to eliminate the" grandfather clause" that permits operators of pipelines installed before November 12, 1970, to operate at levels of stress that exceed those levels permitted for pipelines installed after the effective date. In its letter of September 2, 1992, RSPA advised the Safety Board that on December 11, 1989, it had issued a rulemaking proposal and invited the public to comment on the action RSPA should take on the "grandfather clause." RSPA noted that at the time it adopted the grandfather exception, it did not have information to justify requiring operators to lower the pressure in the grandfathered lines. RSPA also conducted a study on the causes and frequency of gas accidents in pipelines operating above 72 percent of the specified minimum yield strength (SMYS) of the steel from which the pipes were manufactured. The September 2, 1992, letter advised the Safety Board that RSPA could not conclude, based on the comments to the rulemaking or on the study results, that grandfathered lines require special treatment when they operate above 72 percent of SMYS. Therefore, on September 9, 1992, RSPA withdrew its rulemaking proposal and asked the Safety Board to close this recommendation. After our review of RSPA's actions, the Safety Board agrees that this recommendation should be closed and has classified Safety Recommendation P-87-9 "Closed--Reconsidered." Safety Recommendation P-87-21 asked RSPA to increase its use of sanctions as a means for motivating operator compliance with Federal pipeline safety standards. OPS and Safety Board staffs compiled information on the compliance actions taken by the OPS before and after issuance of this recommendation. The data show that the OPS reduced its reliance on warning letters from about 70 percent in 1985 to only 20 percent in 1991, the latest year for which that information was available. Conversely, reliance on civil penalties increased each year--from 9 in 1987 to 72 in 1992. Based on this 6-year record of stepping up the use of sanctions to improve operator compliance, the Safety Board has classified Safety Recommendation P-87-21 "Closed--Acceptable Action." Safety Recommendation P-90-21 asked RSPA to "assess existing gas industry programs for educating the public on the dangers of gas leaks and on reporting gas leaks to determine the appropriateness of information provided, the effectiveness of educational techniques used and those techniques used in other public education programs, and based on its findings, amend the public education provision of the Federal regulations. Safety Board and RSPA staff discussed this recommendation on October 29, 1992. During that meeting, Safety Board staff noted that gas-industry public education programs appear to receive less than half as much public recognition as other public education programs, such as those that promote the use of seatbelts and child restraints. Safety Board personnel explained that RSPA needs to identify the techniques that make other public education programs more effective, determine which of them would improve gas-industry programs, and incorporate them into the Federal requirements. On April 5, 1993, the OPS issued Advisory Bulletin ADB-93-02, which directed 11 gas pipeline facility owners and operators to review and assess their continuing education programs as applied to customers and the public." That bulletin included pertinent information on the accidents investigated by the Safety Board, and in part, it cited Safety Recommendation P-90-21. It advised all natural gas owners and operators to review and assess their continuing education programs to "assure that they are in compliance with the provisions of 49 CFR 192.615(d)." Although the bulletin probably prompted most operators to review their programs, the Safety Board does not regard it as responsive to Safety Recommendation P-90-21 or consistent with the discussions on October 29, 1992, between RSPA and Safety Board staff. The Safety Board encourages RSPA to perform the evaluations necessary to accomplish the recommended action and has classified Safety Recommendation P-90-21 “Open--Unacceptable Response.” The Safety Board appreciates the steps RSPA has taken to improve pipeline safety, but we also encourage your continuing support for the objectives not yet realized.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-08-28

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 9/3/2003 9:53:16 AM MC# 2030443 This letter updates the Research and Special Programs Administration's (RSPA) response to the National Transportation Safety Board (NTSB) Safety Recommendations P-90-21, P-98-37 and P-98-38. These three recommendations address the public education programs of pipeline operators and the evaluation of the effectiveness of communications efforts. I request that Safety Recommendations P-90-21, P-98-37, and P-98-38 be reclassified as "CLOSED - Acceptable Action" based on the development of a public awareness program standard for pipeline operators, the deployment of Community Assistance and Technical Services (CATS) inspectors, and other actions taken to promote pipeline information and education.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-12-20

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 01/03/2003 9:49:19 AM MC# 2030015 As discussed in our meeting with NTSB staff on October 24, RSPA asked all major trade associations for the natural gas and hazardous liquid pipeline industry to develop a single consensus standard for their public awareness programs that ensure a higher quality in programs. The result was a Joint Task Force led by the American Petroleum Institute (APT) to initiate a revision to its Recommended Practice (RP 1123), Development of Public Awareness Programs. The Interstate Natural Gas Association of America (INGAA), the American Gas Association and the American Public Gas Association joined API in this effort. The OPS and the National Association of Pipeline Safety Representatives are participating as observers. The Task Force conducted several focus-surveys of public and local officials and emergency response personnel to determine their public education and communications needs. They reviewed several studies (including the Wirthlin Study conducted by the INGAA and an analysis of best practices by API) and incorporated lessons learned into the initial drafting of the new RP. The effort is expected to result in a significantly different RP. API has withdrawn the current RP 1123 and is issuing the new RP under another number and name, RP 1162, Public Awareness Programs for Pipeline Operators. The RP guidelines will be applicable to: · Intrastate and interstate hazardous liquid pipelines, · Intrastate and interstate natural gas transmission pipelines, · Natural gas distribution pipelines, and, · Gathering pipeline operators. This new RP 1162 will provide pipeline operators guidelines for their public awareness programs and for program expansion to enhance outreach. The overall goal is to enhance public safety and environmental protection through increased public awareness and knowledge. The document defines program objectives and stakeholder audiences, discusses recommended message content, delivery methods used, program documentation and record keeping, and defines evaluation methods to test program effectiveness. A public review draft is currently available on API's website located at: http://www.api.org/pipelinepublicawareness/. OPS has actively encouraged all stakeholders to review and comment on the recommended practice as it is developed to ensure the success of this effort. These stakeholders include landowners, residents, businesses, schools, local and state emergency planning and response agencies, local officials, governing councils, land developers, excavators, and all pipeline operators. The final document will be published in accordance with the approval process under API's consensus standard-making authority established with the American National Standard Institute (ANSI). The Task Force will produce the ANSI document by Spring 2003. OPS frequently adopts industry-developed standards by reference and will likely adopt all or part of this new RP once it is completed. Such action will be subject to the rulemaking process. On January 29, 2003, RSPA will host a public meeting on pipeline communications where our agenda will focus on the adequacy of the draft RP 1162 as well as recent RSPA initiatives, integrity management communications and pipeline performance metrics. Panelists at the meeting will include representatives from various communities, environmental organizations, first responders, city/county government, state government and pipeline companies. The record of comments at this public meeting will help us evaluate the adequacy of RP 1162 and determine the extent to which it meets our regulatory needs. Other communications and public education initiatives include the development of an online resource for pipeline materials and information referred to as "Pipeline 101" and a collaborative project with the National Association of State Fire Marshals to prepare first responders to better respond to pipeline emergencies and to enlist their help in damage prevention and education of state and local officials about pipelines. RSPA has also contracted with the National Academy of Sciences, Transportation Research Board to conduct a study of options to prevent encroachment on pipelines. RSPA also has hired five full-time Community Assistance and Technical Services (CATS) inspectors to help States and industry improve public awareness programs. These initiatives help us improve the adequacy of public education about pipeline risks. While the creation of a new recommended practice and regulation are important methods of assuring that the public is well informed, RSPA has taken additional alternative measures to ensure that public education is improved. By broadening public information on our web site, preparing fire service representatives to address community needs, and by having OPS representatives address state and local officials needs, RSPA will improve the public education processes.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-12-24

Communication Type: Official Correspondence

Communication Contents: RSPA IS PREPARING AN ADVISORY BULLETIN DIRECTING OPERATORS TO REVIEW AND ASSESS THEIR CONTINUING EDUCATION PROGRAMS AIMED AT THEIR CUSTOMERS AND THE PUBLIC RSPA NOTED IN THE LETTER THAT IT WOULD CONTINUE TO WORK WITH THE AMERICAN GAS ASSOCIATION AND OTHER TRADE ASSOCIATIONS IN THIS REGARD BECAUSE IT BELIEVES THAT THEY HAVE A MAJOR ROLE TO PLAY IN ASSESSING THE EFFECTIVENESS OF INDUSTRY PUBLIC AWARENESSS PROGRAMS AND INFORMING OPERATORS OF ESPECIALLY PERSUASIVE APPROACHES.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1994-02-24

Communication Type: Official Correspondence

Communication Contents: ON APRIL 5, 1993, THE OPS ISSUED ADVISORY BULLETIN ADB-93-02 WHICH DIRECTED "..GAS PIPELINE FACILITY OWNERS AND OPERATORS TO REVIEW AND ASSESS THEIR CONTINUING EDUCATION PROGRAMS AS APPLIED TO CUSTOMERS AND THE PUBLIC."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1990-09-28

Communication Type: Official Correspondence

Communication Contents: OPS WILL EXPLORE SOURCES OF FUNDING AVAILABLE IN FY 1991 FOR ASSESSING EXISTING GAS INDUSTRY PROGRAMS FOR EDUCATIONAL THE PUBLIC ON THE DANGERS OF GAS LEAKS AND THE IMPORTANCE REPORTING GAS LEAKS. PROVIDED FUNDING IS AVAILABLE, WE WILL TASK RSPA'S TRANSPORTATION SYSTEMS CENTER IN CAMBRIDGE, MA. TO CONDUCT THE ASSESSMENT.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-10-30

Communication Type: Official Correspondence

Communication Contents: RSPA'S CURRENT EFFORTS AT INCREASING PUBLIC AWARENESS WILL FULLY ADDRESS BOTH OF THESE RECOMMENDATIONS (P-90-21 & P-97-14). RSPA CONTINUES TO MEET REGULARLY WITH REPRESENTATIVES OF STATE AND FEDERAL AGENCIES, PIPELINE OPERATORS, EXCAVATORS, AND OTHERS TO ADDRESS DAMAGE PREVENTION ISSUES. RSPA'S DAMAGE PREVENTION ACCOMPLISHMENTS INCLUDE; 1) PASSAGE BY CONGRESS OF THE ONE-CALL NOTIFICATION PROVISIONS OF THE TRANSPORTATION EQUITY ACT FOR THE 21ST CENTURY (TEA-2 1), WHICH WERE BASED ON DRAFT LEGISLATION SUPPORTED BY DOT, THE PIPELINE INDUSTRY, AND OPERATORS OF OTHER UNDERGROUND FACILITIES; 2) IMPLEMENTATION OF A RULE REQUIRING OPERATORS OF ONSHORE GAS, HAZARDOUS LIQUID AND CARBON DIOXIDE PIPELINES TO PARTICIPATE IN QUALIFIED ONE-CALL SYSTEMS AS PART OF THE EXCAVATION DAMAGE PREVENTION PROGRAMS REQUIRED BY THE PIPELINE SAFETY REGULATIONS; 3) FORMATION OF RSPA'S DAMAGE PREVENTION QUALITY ACTION TEAM (DAMQAT), WHICH INCLUDES GROUPS WITH A SIGNIFICANT INTEREST IN DAMAGE PREVENTION, INCLUDING STATES, PROFESSIONAL EXCAVATORS, ONE-CALL CENTERS, INSURANCE AND TELECOMMUNICATIONS COMPANIES; AND 4) LAUNCH OF THE PILOT DAMAGE PREVENTION EDUCATION CAMPAIGN. DAMQAT CONDUCTED A NATIONWIDE, IN-DEPTH STUDY OF DAMAGE PREVENTION AWARENESS AND EXCAVATION PRACTICES. THE STUDY DOCUMENTED THE DAMAGE PREVENTION PRACTICES THAT ARE GENERALLY OBSERVED AND THOSE WHICH NEED TO BE ADOPTED. THIS WAS THE FIRST IN-DEPTH NATIONWIDE SURVEY OF KEY GROUPS: PROFESSIONAL EXCAVATORS, STATE, COUNTY AND MUNICIPAL PUBLIC WORKS EMPLOYEES, FACILITY OPERATORS AND THE PUBLIC. DAMQAT HAS CONDUCTED A SURVEY TO EVALUATE THE LEVEL OF DAMAGE PREVENTION AWARENESS AND DAMAGE PREVENTION PRACTICES. THE SURVEY DISCUSSED ABOVE PROVIDED BASELINE DATA ON DAMAGE PREVENTION AWARENESS AND EXCAVATION PRACTICES FOR DESIGN OF MATERIALS FOR A ONE-CALL PUBLIC AWARENESS CAMPAIGN THAT WILL ENABLE RSPA TO GAUGE THE SUCCESS OF THE PILOT EDUCATION PROGRAM. RSPA LAUNCHED ITS PILOT DAMAGE PREVENTION AWARENESS CAMPAIGN IN THREE STATES TO ASSESS THE EFFECTIVENESS OF THE PROGRAM BEFORE NATIONWIDE IMPLEMENTATION. THESE ACTIVITIES ARE AIMED AT ENSURING THAT THE EXCAVATING COMMUNITY UNDERSTANDS THE IMPORTANCE OF FULL PARTICIPATION IN DAMAGE PREVENTION ACTIVITIES, EFFECTIVE PIPELINE MARKING PRACTICES, THE IMPORTANCE OF ADEQUATE MAPPING AND LOCATION OF PIPELINES, AND EMERGENCY RESPONSE PLANNING TO AMELIORATE THE CONSEQUENCES OF DAMAGE TO PIPELINES. RSPA IS ALSO ESTABLISHING A NEW TEAM OF GOVERNMENT, INDUSTRY, AND PUBLIC REPRESENTATIVES TO COMPLETE A STUDY OF BEST PRACTICES IN DAMAGE PREVENTION AND TO PROMOTE INFORMATION SHARING AMONG ALL INTERESTS INVOLVED IN UNDERGROUND FACILITY DAMAGE PREVENTION. THE TEAM WILL EVALUATE THE EFFECTIVENESS OF VARIOUS EXISTING ONE-CALL NOTIFICATION SYSTEMS IN PROTECTING THE PUBLIC, INDIVIDUALS ENGAGING IN EXCAVATION ACTIVITIES AND THE ENVIRONMENT, AND IN PREVENTING DISRUPTIONS TO PUBLIC SERVICES AND DAMAGE TO UNDERGROUND FACILITIES. RSPA CONDUCTED A PUBLIC MEETING ON 8/25-26/98, TO SOLICIT VIEWS AND RECOMMENDATIONS ON THIS STUDY OF ONE-CALL SYSTEM BEST PRACTICES. THE ATTENDEES REPRESENTED ALL PARTS OF THE DAMAGE PREVENTION COMMUNITY. THE ONE-CALL BEST PRACTICES STUDY TEAM IS NOW BEING ESTABLISHED AND WILL MEET OVER THE NEXT YEAR TO IDENTIFY AND EVALUATE ONE-CALL BEST PRACTICES FROM THROUGHOUT NORTH AMERICA. WITH RESPECT TO P-90-21, 49 CFR SECTION 192.616 OF THE PIPELINE SAFETY REGULATIONS REQUIRES OPERATORS TO ESTABLISH AND MAINTAIN AN EDUCATIONAL PROGRAM TO ENABLE PERSONS TO RECOGNIZE A GAS PIPELINE EMERGENCY FOR THE PURPOSE OF REPORTING IT TO THE OPERATOR OR APPROPRIATE PUBLIC OFFICIALS. ADDITIONALLY, RSPA BELIEVES THAT THE BASIS OF THIS RECOMMENDATION HAS BEEN OVERTAKEN BY SUBSEQUENT EVENTS. DAMQAT'S PUBLIC EDUCATION ACTIVITIES ARE AIMED AT ENHANCING THE UNDERSTANDING OF THE EXCAVATING COMMUNITY OF THE IMPORTANCE OF FULL PARTICIPATION IN DAMAGE PREVENTION ACTIVITIES. THESE ACTIONS ARE PROACTIVE STEPS TAKEN BEFORE A GAS LEAK OCCURS. DAMQAT'S EFFORTS WILL BE ENHANCED BY THOSE OF THE DAMAGE PREVENTION BEST PRACTICES TEAM, WHICH WILL INCLUDE INVESTIGATING AND EVALUATING THE CURRENT PRACTICES IN THE DAMAGE PREVENTION COMMUNITY. PART OF THIS EVALUATION WILL BE OF PRACTICES IN INCREASING PUBLIC AWARENESS IN DAMAGE PREVENTION, AS WELL AS REPORTING AND EVALUATION OF DAMAGE PREVENTION PROCESS. RSPA BELIEVES THAT THESE EFFORTS FULLY ADDRESS THE CONCERNS RAISED IN THIS RECOMMENDATION, AND WE REQUEST THAT P-90-21 BE CLASSIFIED AS "CLOSED--RECONSIDERED."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-04-09

Communication Type: Official Correspondence

Communication Contents: FUNDING WAS NOT AVAILABLE IN FY 1991 NOR IN 1992 TO ASSESS EXISTING GAS INDUSTRY PUBLIC EDUCATION PROGRAMS. IN LIGHT OF CURRENT AND PROJECTED BUDGET CONSTRAINTS, WE VIEW SUCH AN ASSESSMENT AS A LOW PRIORITY FOR FUNDING. WE BELIEVE THAT TRADE ASSOCIATIONS SUCH AS THE AGA SHOULD MORE APPROPRIATELY TAKE RESPONSIBILITY FOR ASSESSING GAS INDUSTRY PUBLIC EDUCATION PROGRAMS.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2000-04-24

Communication Type: Official Correspondence

Communication Contents: Public Education: NTSB Safety Recommendations P-90-21, P-98-37, and P-98-38 address the possible need to change the public education requirement in the pipeline safety regulations. RSPA is actively encouraging the improvement in public education about pipeline safety, expecially through our damage prevention efforts. In addition, we are now working with the pipeline industry to assess public education efforts beyond those dealing with damage prevention to underground facilities. RSPA is evaluating industry approaches to educating the public by working with the American Petroleum Institute and other pipeline industry trade associations. RSPA is also considering a survey of pipeline companies to review and evaluate the effectiveness of their public education programs in enhancing pipeline safety in local communities. RSPA may require a communications plan as part of an integrity management program. Industry and public interest group representatives, such as the National League of Cities, the Environmental Defense Fund, and the national organization of Local Emergency Planning Committees, are working to develop some models on communications and public education that can be pilot tested to determine what kind of information is most beneficial to local officials in preventing and responding to pipeline spills. RSPA is also considering proposing requirements for how operators communicate with local officials about results of risk assessment processes and measures to prevent and mitigate damage to pipelines in case of a failure. RSPA is seeking information on how local officials could use and benefit from risk assessment information, how the consequences of potential pipeline failures should be characterized, how risk control actions should be described and what performance indicators would be meaningful.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1991-05-07

Communication Type: Official Correspondence

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1990-09-26

Communication Type: Official Correspondence

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-08-31

Communication Type: Official Correspondence