NTSB Safety Recommendation P-97-020

NTSB safety recommendation P-97-020.

THE NTSB RECOMMENDS THAT THE RSPA: DEVELOP & DISTRIBUTE TO PIPELINE OPERATORS WRITTEN GUIDANCE TO IMPROVE THE ACCURACY OF INFO FOR REPORTABLE ACCIDENTS, INCLUDING PARAMETERS FOR ESTIMATING PROPERTY DAMAGE RESULTING FROM AN ACCIDENT.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1998-01-06

Adopted Date: 1997-12-23

Overall Date Closed: 2004-04-29

Synopsis: THE SAFETY BOARD HAS LONG BEEN CONCERNED ABOUT THE NUMBER OF EXCAVATION-CAUSED PIPELINE ACIDENTS. IN RESPONSE TO SIX SERIOUS PIPELINE ACCIDENTS DURING 1993 AND 1994 THAT WERE CAUSED BY EXCAVATION DAMAGE AND TO FOSTER IMPROVEMENTS IN STATE EXCAVATION DAMAGE PREVENTION PROGRAMS, THE SAFETY BOARD AND THE RSPA JOINTLY SPONSORED A WORKSHOP IN SEPTEMBER 1994. THIS WORKSHOP BROUGHT TOGETHER ABOUT 400 REPRESENTATIVES FROM PIPELINE OPERATORS, EXCAVATORS, TRADE ASSOCIATIONS, AND LOCAL, STATE, AND FEDERAL GOVERNMENT AGENCIES TO IDENTIFY AND RECOMMEND WAYS TO IMPROVE PREVENTION PROGRAMS. THE SAFETY BOARD RECENTLY COMPLETED A SAFETY STUDY THAT ANALYZED THE FINDINGS OF THE 1994 WORKSHOP, DISCUSSED INDUSTRY AND GOVERNMENT ACTIONS UNDERTAKEN SINCE THE WORKSHOP, AND FORMALIZED RECOMMENDATIONS AIMED AT FURTHER ADVANCING IMPROVEMENTS IN EXCAVATION DAMAGE PREVENTION PROGRAMS.

Ntsbnumber: 80433

Report Number: SS-97-01

Addressee Name: RSPA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2004-04-29

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-10-21

Communication Type: Official Correspondence

Communication Contents: THE BOARD WOULD APPRECIATE BEING ADVISED OF ANY ACTIONS THAT RSPA HAS TAKEN OR PLANS TO TAKE ON EACH OF THESE RECOMMENDATIONS. COPIES OF OUR 1/6/98, & OUR 4/30/98, CORRESPONDENCE ARE ENCLOSED.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-04-18

Communication Type: Official Correspondence

Communication Contents: THE SAFETY BOARD APPRECIATES THE UPDATE ON ACTIONS TO IMPLEMENT P-97-14 THROUGH -24 AND P-99-1. WITH RESPECT TO P-97-20 THROUGH -24, WHICH RELATE TO ACCIDENT REPORTING AND THE COLLECTION AND USE OF DATA THE SAFETY BOARD NOTES THAT YOUR LETTER DID NOT PROVIDE SPECIFIC INFORMATION ON ACTIONS BEING TAKEN IN RESPONSE TO THESE RECOMMENDATIONS. PENDING AN UPDATE FROM RSPA ON THESE ISSUES, P-97-20 THROUGH -24 WILL REMAIN CLASSIFIED "OPEN--ACCEPTABLE RESPONSE."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-06-29

Communication Type: Official Correspondence

Communication Contents: P-97-20 ASKED THAT RSPA DEVELOP AND DISTRIBUTE TO PIPELINE OPERATORS WRITTEN GUIDANCE TO IMPROVE THE ACCURACY OF INFORMATION FOR REPORTABLE ACCIDENTS, INCLUDING PARAMETERS FOR ESTIMATING PROPERTY DAMAGE RESULTING FROM AN ACCIDENT. AS RSPA IS WORKING WITH THE INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA (INGAA) AND THE AMERICAN PETROLEUM INSTITUTE (API) TO IMPROVE ACCIDENT DATA COLLECTION INFORMATION, ESPECIALLY RELATED TO EXCAVATION DAMAGE, AND WILL THEN APPLY IT TO IMPROVE INFORMATION COLLECTED, P-97-20 AND -21 HAVE BEEN CLASSIFIED "OPEN--ACCEPTABLE RESPONSE," PENDING FURTHER INFORMATION FROM RSPA ON THE STATUS OF IMPLEMENTING THE RECOMMENDATIONS. THE BOARD ENCOURAGES RSPA TO STAY ON TOP OF THESE INITIATIVES AND TO ENSURE THAT THE COLLECTED DATA IS APPLIED TO MANDATORY REQUIREMENTS.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-11-26

Communication Type: Official Correspondence

Communication Contents: The Safety Board understands that RSPA is working to improve reporting of accidents and estimation of property damages. Specifically, RSPA has proposed changes to the forms and instructions for the natural gas transmission pipeline incident and annual reports and the hazardous liquid pipeline accident report to improve the quality of pipeline failure data. The Board notes that the new reporting instructions are available to the public on the Office of Pipeline Safety (OPS) Web site: www.ops.dot.gov (Online Library; Forms section). Secondly, RSPA is currently drafting an advisory bulletin to provide additional guidance to pipeline operators on estimating property damage from pipeline accidents, including information on supplemental damage reporting after the initial report is filed. Further, the advisory bulletin will discuss how pipeline companies can contribute to improving the quality of data and discusses RSPA's data improvement initiatives. In addition, RSPA reports that frequently asked questions will be posted on the OPS website following the publication of the advisory bulletin, which will be updated to reflect questions on data and data reporting posed by pipeline operators and the public. Accordingly, because RSPA is making progress on implementing this recommendation, Safety Recommendation P-97-20 is classified "Open--Acceptable Response," pending notification from RSPA that the actions described above have been completed.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-04-29

Communication Type: Official Correspondence

Communication Contents: The Safety Board understands that RSPA has taken a number of actions, including the following: · In May 2001, RSPA published a final notice to implement revised forms, RSPA F7100.2, Incident Report for Gas Transmission and Gathering Systems, and RSPA F7100.2-1, Annual Report for Gas Transmission and Gathering Systems, to improve reporting of accident data and of estimated property damages. · In January 2002, RSPA published a final rule that changed the reporting requirements for hazardous liquid pipeline accidents and made similar changes to RSPA F7001-1, Accident Report-Hazardous Liquid Pipeline Systems. This rule lowered the current release-reporting threshold of 50 barrels to a new threshold of 5 gallons and changed the "bodily harm" criteria for accident reporting to conform to the gas pipeline reporting requirements. · Since 2002, RSPA has improved data collection following the adoption of the ASME B31.4 Committee's reports regarding proposed failure cause categories for both hazardous liquid and natural gas transmission. · RSPA has created a new accident report region review tracking system for regional staff use to audit filed incident and accident reports to ensure complete, accurate, and timely information submission and to track requests to operators for supplemental information. · In January 2004, RSPA published a final rule to require hazardous liquid operator annual reports. The Board notes that RSPA will not publish an advisory bulletin to provide additional guidance to pipeline operators on estimating property damage, because RSPA's actions as detailed in your letter obviate such a bulletin. Because the actions taken by RSPA fully address the recommendation, Safety Recommendation P-97-20 is classified "Closed--Acceptable Action."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-02-17

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 2/24/2004 12:09:18 PM MC# 2040085 On May 8, 2001, RSPA published a final notice to implement revised forms, RSPA F7100.2, Incident Report for Gas Transmission and Gathering Systems, and RSPA F 7100.2-1, Annual Report for Gas Transmission and Gathering Systems (65 FR 47585-86, August 2, 2000) to improve reporting of accident data and of estimated property damages. The two new forms were distributed to operators and data collection began January 1, 2002. The improved forms will provide pipeline mileage by decade installed and by class location. The reporting instructions and forms are available on the OPS website: http://ops.dot.gov under the section for ONLINE LIBRARY and FORMS. These are just two of the four-gas pipeline reporting forms we have revised. In June 2003 (68 FR 33759) and December 31, 2003 (68 FR75720) RSPA published Federal Register Notices seeking comments on the proposed changes in the natural gas distribution incident and annual report forms. We expect the revised forms to become effective on March 1, 2004. On January 8, 2002, RSPA published a final rule that changes the reporting requirements for hazardous liquid pipeline accidents and similar changes to RSPA F 7001-1, Accident Report - Hazardous Liquid Pipeline Systems. The rule lowered the current release-reporting threshold of 50 barrels to a new threshold of live gallons and changed the "bodily harm" criteria for accident reporting to conform to the gas pipeline reporting requirements. On February 7, 2002, RSPA/OPS collected data from the revised hazardous liquid accident reports. As recommended by NTSB, improved data has been collected since calendar year 2002 following the adoption of the ASME B 31.4 Committee's proposed failure cause categories for both hazardous liquid and natural gas transmission reports. RSPA not only adopted ASME's 22 categories but also added three other categories. These include expanded data on the location and consequences of accidents, expanded breakouts for property damage by cost of lost products, cost to the operator, and costs to the public or others. RSPA implemented improved instructions on how to report costs and complete the new forms. In 2002, RSPA implemented an electronic reporting option for the new forms with online help and mandatory fields to ensure complete, accurate information, including the required categories for property damages. RSPA also added an "open/closed" indicator to provide for updates to incident report status. Check boxes requesting "Initial," "Supplemental" and "Final" report have been added along with guidance on filing supplemental reports when complete costs, consequences, cause, or other information is confirmed. RSPA has also created a new Accident Report Region Review Tracking System for regional staff use to audit filed incident and accident reports to ensure complete, accurate, and timely information submission and to track requests to operators for supplemental information. In 2002, RSPA published a Notice of Proposed Rulemaking for a new hazardous liquid operator annual report that would provide information about hazardous liquid pipelines similar to that currently collected for natural gas operators. RSPA/OPS published a Final Rule to require hazardous liquid operator annual reports on January 6, 2004. In our letter of July 13, 2001, RSPA had planned to publish an advisory bulletin to provide additional guidance to pipeline operators on estimating property damage. However, this effort is no longer needed as we have since distributed the new forms and improved instructions to all pipeline operators.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-07-13

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 07/20/2001 4:24:14 PM MC# 2010585 RSPA is working to improve reporting of accidents and estimation of property damages: ·RSPA has proposed changes to the forms and instructions for the natural gas transmission pipeline incident and annual reports and the hazardous liquid pipeline accident report to improve the quality of pipeline failure data. This is discussed further in our updated response to Safety Recommendation P-97-2 1. The new reporting instructions are available to the public on the OPS website: ops.dot.gov under the ONLINE LIBRARY in the FORMS section. ·RSPA is currently drafting an Advisory Bulletin for publication by September 2001 to provide additional guidance to pipeline operators on estimating property damage from pipeline accidents, including information on supplemental damage reporting after the initial report is filed. The Advisory Bulletin also discusses how pipeline companies can contribute to improving the quality of data and discusses RSPA's data improvement initiatives. ·Frequently asked questions will be posted on the OPS website following the publication of the Advisory Bulletin and will be updated to reflect questions on data and data reporting posed by pipeline operators and the public. Action Requested: RSPA requests that Safety Recommendation P-97-20 be reclassified as "Open - Acceptable Action" while we continue to pursue the actions described above.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-10-30

Communication Type: Official Correspondence

Communication Contents: RSPA SUPPLIED NTSB WITH A DRAFT OF THE PROPOSED PILOT FOR HAZARDOUS LIQUID DATA COLLECTION ON 6/12/98. THE PILOT LIQUID DATA PLAN IS BEING TESTED BY MEMBER COMPANIES OF THE AMERICAN PETROLEUM INSTITUTE. WE PLAN TO EXPAND THE NUMBER OF 'CAUSE' CATEGORIES TO 22 IN ORDER TO GATHER BETTER ACCIDENT DATA, INCLUDING PRECURSOR EVENTS, SUCH AS INTENDED PURPOSE OF EXCAVATION, APPROPRIATE USE OF ONE CALL NOTIFICATION CENTERS, AND AN ADDITIONAL FOCUS ON EXCAVATION DAMAGE AS DESCRIBED IN THE PILOT PLAN. RSPA ANTICIPATES TIMELY FEEDBACK FROM NTSB AS WE MOVE FORWARD WITH THIS PILOT TO GREATLY IMPROVE OUR LIQUID ACCIDENT DATA COLLECTION. FOR GAS DATA, THE INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA (INGAA) IS DEVELOPING ITS OWN DATA SYSTEM TO TRACK INCIDENT-RELATED DATA THAT WILL PROVIDE INSIGHT INTO ROOT CAUSES OF ACCIDENTS AND HELP IDENTIFY SAFETY IMPROVEMENTS. RSPA'S UNDERSTANDING OF THE DATA THAT THE INDUSTRY WILL COLLECT WAS IMPROVED BY OUR JOINT FEDERAL/INDUSTRY/STATE GAS DATA TEAM. MUTUAL DEVELOPMENT OF ELECTRONIC INCIDENT REPORTING IS BEING DISCUSSED. IT IS POSSIBLE THAT THE NATURAL GAS INDUSTRY'S DATA COLLECTION SYSTEM WILL PROVIDE USEFUL DATA FOR IMPROVING UNDERSTANDING OF SAFETY ISSUES IT IS UNCLEAR AT THIS TIME HOW SUCCESSFUL THIS ENDEAVOR MAY BE AND HOW DATA IN THE GAS INDUSTRY'S DATA COLLECTION SYSTEM WILL BE SHARED WITH RSPA. LESSONS LEARNED FROM OUR HAZARDOUS LIQUID DATA IMPROVEMENT PILOT PROJECT MAY PROVIDE INSIGHT INTO HOW THE GAS INDUSTRY DATA SYSTEM CAN SHARE DATA WITH RSPA. WE ARE CONSIDERING ESTABLISHING A DATA TEAM TO EXPAND ON THE INITIAL EFFORTS OF LAST YEAR'S GAS INDUSTRY TEAM. WE WILL ALSO WORK WITH THE AMERICAN PUBLIC WORKS ASSOCIATION, ONE CALL SYSTEMS INTERNATIONAL (OCSI) AND OTHER INTERESTED PARTIES TO STANDARDIZE THE WAY THE ONE-CALL INDUSTRY COLLECTS AND CATEGORIZES DATA ON PIPELINE ACCIDENTS AND THEIR CAUSES. WE BELIEVE RSPA'S EFFORTS TO IMPROVE THE COLLECTION OF UNDERGROUND EXCAVATION DAMAGE DATA AND TO BETTER EMPLOY THIS DATA FULLY ADDRESS THE RECOMMENDATIONS. RSPA REQUESTS THAT P-97-20 THROUGH -24 BE CLASSIFIED AS "CLOSED--ACCEPTABLE ACTION."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2000-04-24

Communication Type: Official Correspondence

Communication Contents: On June 30, 1999, RSPA co-sponsored a public meeting in Washington, DC, to present a report on damage prevention best practices. The report was developed by over 160 volunteers representing a broad spectrum of damage prevention stakeholders who worked for almost a year to produce a report on best practices in damage prevention, known as the Common Ground Study. This report covered virtually every aspect of damage prevention from design and planning, through locating and safe excavation practices. It has become the manual of choice for those involved in damage prevention. We are gratified that you were able to join us to present this report to Transportation Secretary Rodney Slater. RSPA is now facilitating the establishment of a non-profit organization to advance underground damage prevention, consistent with the cooperative spirit of the Common Ground team. RSPA held a public meeting on October 28, 1999, in Baltimore, Maryland, to elaborate the elements of an effective non-profit organization, including possible mission statements, goals, functions, guiding principles, and organizational structure. NTSB's Jack Fox participated in this event. On February 17, 2000, a broad-based coalition of industry leaders in the pipeline and underground damage prevention communities met to launch the teams that will develop and staff the new organization. RSPA believes that with the support of Congress and the U.S. Department of Transportation (DOT), we can provide the necessary resources to initiate the creation of a self-sustaining private sector non-profit organization and ensure the participation of all affected stakeholders. We believe this organization will provide an effective forum for information sharing among all stakeholders in damage prevention. This will include regular interaction with the affected industries in the damage prevention community. We believe the organization can contribute to creative solutions to underground damage prevention issues and to our attempts to respond fully to a number of "Open" NTSB Safety Recommendations, including P-97-14 through 24, and P-99-1. In addition, RSPA has been deploying a national damage prevention public education campaign, known as the Dig Safely campaign. This effort dates back to October 1996, when we formed the Damage Prevention Quality Action Team (DAMQAT). This team included a broad spectrum of representatives: professional excavators, one-call centers, insurance, telecommunications, operators of hazardous liquid, natural gas transmission and distribution lines as well as state pipeline safety agencies, and RSPA's OPS. The DAMQAT conducted an extensive examination of the problem, including a nationwide survey of 1500 respondents from the excavator, facility operator, and public works communities, as well as the general public. DAMQAT used the results of the national survey to develop a "tag line," a message, and a design for education campaign materials. These materials included a safety video, print ads for trade publications, a radio public service announcement, brochures, and bill inserts. These were field tested for six months in three states, Virginia, Georgia, and Alabama. Pre-pilot and post-pilot surveys enabled the team to judge the effectiveness of the materials. Data collected from the three states indicate a sharp increase in recognition of the four basic messages of the campaign: call before you dig, wait the required time, observe the marks, and dig with care. All three states reported a decline in excavation-related damage to underground facilities. In addition, DAMQAT commissioned a training manual for those who want to use the campaign materials. It contains general information on how to conduct a damage prevention campaign, as well as the safety video, and two CD ROMS which contain all the campaign artwork. DAMQAT team members have conducted over thirty Dig Safely training sessions nationwide. Another six are scheduled and more are being planned. The DAMQAT was recently renamed the Dig Safely Team, is expanding its membership and hopes to include other interested parties such as locators, cable TV, electricity, water and sewer. Some of the materials will be translated into Spanish for distribution in areas with a significant Spanish speaking population. The Dig Safely Campaign has been officially endorsed by DOT, the American Petroleum Institute, One Call Systems International, the Association of Oil Pipelines, and the National Telecommunications Damage Prevention Council. The National Energy Board of Canada is considering recommending to the Canadian Government that they adopt the campaign.