PHMSA’s Friendly Reminder: Always Be Prepared

On November 3rd, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin 10-08, reminding gas and hazardous liquid pipeline operators to make available pipeline emergency response plans to local emergency response officials.

There are a few federal regulations that cover these requirements. According to the PHMSA Bulletin, under 49 CFR 192.605, 192.615, and 195.402, “operators must include in their emergency plans provisions for coordinating with appropriate fire, police, and other public officials both preplanned drills and actual responses to pipeline emergencies.” Operators are also obliged to maintain relationships with local emergency officials, and work with them to establish the respective roles and responsibilities in planning for and responding to emergencies.

Photo by RekonDog. Some rights reserved.

Under 49 CFR 192.616 and 195.440, operators must develop a public education program pursuant to the American Petroleum Institute’s Recommended Practice (RP) 1162. (RP 1162 is incorporated by reference into said CFR sections. The full text of the RP can be ordered here for $93.00, though you can browse a PHMSA Power Point on the subject for free.) The RP includes additional requirements for emergency response plans, such as providing information on  “how emergency officials can access the operator’s emergency response plan.”

All this to ensure that in the event of a pipeline-related emergency, things go as smoothly as possible, ideally benefiting from the required communication and practiced responses. But public safety shouldn’t be your only motivation in updating response plans:  PHMSA intends to “evaluate the extent to which operators have provided their emergency plans to local emergency officials when PHMSA performs future inspections for compliance with liaison and public awareness code requirements.” As Van Ness Feldman points out, this Bulletin suggests that “PHMSA plans to target enforcement efforts in this area. In light of recent pipeline accidents in California, Michigan, and Texas, PHMSA’s focus on emergency preparedness is likely to remain strong.”

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