NTSB Safety Recommendation P-97-021

NTSB safety recommendation P-97-021.

THE NTSB RECOMMENDS THAT THE RSPA: AS PART OF THE COMPREHENSIVE PLAN FOR THE COLLECTION AND USE OF GAS AND HAZARDOUS LIQUID DATA, REVISE THE CAUSE CATEGORIES ON THE ACCIDENT REPORT FORMS TO ELIMINATE OVERLAPPING AND CONFUSING CATEGORIES AND TO CLEARLY LIST EXCAVATION DAMAGE AS ONE OF THE DATA ELEMENTS, AND CONSIDER DEVELOPING CATEGORIES THAT ADDRESS THE PURPOSE OF THE EXCAVATION.

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-97-21 ASKED THAT RSPA, AS PART OF THE COMPREHENSIVE PLAN FOR THE COLLECTION AND USE OF GAS AND HAZARDOUS LIQUID DATA, REVISE THE CAUSE CATEGORIES ON THE ACCIDENT REPORT FORMS TO ELIMINATE OVERLAPPING AND CONFUSING CATEGORIES AND TO CLEARLY LIST EXCAVATION DAMAGE AS ONE OF THE DATA ELEMENTS, AND CONSIDER DEVELOPING CATEGORIES THAT ADDRESS THE PURPOSE OF THE EXCAVATION. 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 during the last several years, RSPA has taken action to improve the quantity of data it collects on pipeline accidents as well as the quality of this data. Specifically, RSPA has proposed changes to the natural gas transmission pipeline annual and incident reports and to the hazardous liquid pipeline accident reports; these proposals include revising the cause categories, listing excavation damage separately, and eliminating overlapping cause categories. Other proposed changes include enhancements to RSPA's natural gas transmission pipeline annual and incident reporting requirements to provide important information to more completely characterize the existing infrastructure and to more accurately identify the causes of incidents. Reportedly, the revised RSPA gas incident and annual report forms will provide better cause, cost, and consequence information (including excavation damage as primary cause), more specific data on what part of the system failed, online reporting for faster data reporting and quality control, better tracking of supplemental reports, and improved instructions and guidance for completing the forms. In addition, the Board understands that RSPA has proposed revisions to its liquid accident reporting requirements that lower the threshold for filing reports and provide greatly expanded cause information. Reportedly, under this proposal, the hazardous liquid pipeline spill reporting threshold is reduced to 5 gallons from 50 barrels (2,100 gallons), and pipeline operators are required to more accurately describe accident causes and to provide better data on smaller accidents that may be indicators of future integrity issues. Also, RSPA is finalizing a proposal to require hazardous liquid operators to submit annual accident and inventory reports, which would be similar to those reports filed by natural gas transmission operators. This information would provide critically needed mileage data to statistically normalize hazardous liquid pipeline leak rates, which would improve the ability to characterize and rank operator performance. The Board further notes that RSPA is monitoring the progress of the voluntary incident reporting system implemented by the American Petroleum Institute (API), which is in addition to the proposed improvements in mandatory data collection. The API system tracks spills to waterways as small as 1 gallon and will collect more detailed information than RSPA can justify under the Paperwork Reduction Act requirements. The Board understands that the API has already collected data for CY 1999 and CY 2000, that the API will provide this information to participating pipeline companies for baseline safety performance comparisons, and that aggregate information will be made available to RSPA when enough information for trending has been collected. Accordingly, pending further information from RSPA on the status of these initiatives, Safety Recommendation P-97-21 is classified "Open--Acceptable Response."

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 implemented changes to the natural gas transmission pipeline annual and incident reporting requirements, and to the liquid accident reporting forms, as follows: ·revised of the cause categories; ·separated listing for excavation damage; ·addressed the purpose of the excavation; ·obtained information about the effectiveness of one-call and other mitigative efforts in place at the time of the accident; ·eliminated overlapping cause categories; and ·amended the natural gas distribution incident and annual report forms. In addition, RSPA issued a final rule requiring the filing of the revised hazardous liquid accident report by January 8, 2002, and the spill reporting threshold for hazardous liquid pipelines was dramatically reduced to 5 gallons from 50 barrels (2,100 gallons). The accident report form now requires accident causes to be described more accurately and will provide better data on smaller accidents that should serve as indicators of larger problems. Because these initiatives satisfactorily addressed the recommendation, Safety Recommendation P-97-21 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 During the last several years, RSPA has implemented changes to the natural gas transmission pipeline annual and incident reporting requirements and to the liquid accident reporting forms as discussed above in P-97-20. These improvements include revisions to the cause categories, listing excavation damage separately, addressing the purpose of the excavation, and obtaining information about the effectiveness of one-call and other mitigative efforts in place at the time of the accident, and eliminating overlapping cause categories, and other changes. On March 20, 2001, RSPA proposed revisions to its hazardous liquid accident reporting requirements that both lower the threshold for filing reports and provide greatly expanded information on causes of those accidents. RSPA issued a Final Rule requiring the filing of the revised hazardous liquid accident report by January 8,2002, with an effective date of February 7, 2002. The hazardous liquid pipeline spill reporting threshold was dramatically reduced to five gallons from 50 barrels (2,100 gallons). The new accident report form requires accident causes to be described more accurately and will provide better data on smaller accidents that might serve as indicators of larger problems. Finally, 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. RSPA requests P-97-21 be classified "CLOSED--Acceptable Action."

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 During the last several years, RSPA has taken decisive action to improve the quantity of data it collects on pipeline accidents and on the quality of this data. As discussed above, RSPA has proposed changes to the natural gas transmission pipeline annual and incident reports and to the hazardous liquid pipeline accident reports. These proposals include revisions to the cause categories, listing excavation damage separately, eliminating overlapping cause categories, and other changes as follows: ·RSPA proposed significant enhancements to its natural gas transmission pipeline annual and incident reporting requirements in August 2000. These revisions will provide important information to more completely characterize the existing infrastructure and to more accurately identify the causes of incidents. The revised RSPA gas incident and annual report forms will provide: ·better cause, cost and consequence information (including excavation damage as primary cause), ·more specific data on what part of the system failed, ·online reporting for faster data reporting and quality control, ·better tracking of supplemental reports, and ·improved instructions and guidance for completing the forms. ·RSPA proposed revisions to its liquid accident reporting requirements that lower the threshold for filing reports and provide greatly expanded cause information on March 20, 2001. Under this proposal, the hazardous liquid pipeline spill reporting threshold is reduced to five gallons from 50 barrels (2,100 gallon). The proposal also requires pipeline operators to more accurately describe accident causes and to provide better data on smaller accidents, which may be indicators of future integrity issues. ·RSPA is finalizing a proposal to require hazardous liquid operators to submit annual accident and inventory reports, which would be similar to the reports filed by natural gas transmission operators. This information would provide critically needed mileage data to statistically normalize hazardous liquid pipeline leak rates, which would improve the ability to characterize and rank operator performance. ·RSPA is monitoring the progress of the voluntary incident reporting system implemented by the American Petroleum Institute (API). This effort is in addition to the proposed improvements in mandatory data collection. The API system tracks spills to waterways as small as one gallon and will collect more detailed information than RSPA can justify under the Paperwork Reduction Act requirements. API has already collected data for CY 1999 and CY 2000. API will provide this information to participating pipeline companies for baseline safety performance comparisons. Aggregate information will be made available to RSPA when enough information for trending has been collected.

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 PUROSE 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.