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Pipeline Safety Improvement Act of 2002 Operators of a pipeline facility must carry out

a continuing public education program:› One-call notifications and other damage

prevention activities› Possible hazards with unintended releases› Physical indications of such a release› Steps for public safety in event of release› Procedures to report a release

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Industry began developing recommendations› Liquid and gas transmission, LDC, gatherings

systems, trade associations and regulators Resulted in API RP 1162 To increase effectiveness of public

awareness (PA) in industry, goal of RP was to establish guidelines for:› Development,› Implementation, and› Self evaluation of PA programs.

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First Edition adopted December 2003› Second edition published late 2010

Provide guidance to develop and manage Public Awareness Programs (PAPs)› Raise quality of programs› Establish consistency› Provide mechanisms for continuous

improvement through evaluations

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An effective and consistently managed PAP can add value by:› Improving public understanding and safety› Improving safety and environmental performance› Building trust and better relationships› Lowering resistance to maintenance and ROW

activities› Preserving ROW› Enhancing Emergency Response coordination› Improving pipeline operator reputation

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Designed as resource for PAPs associated with the normal operation of existing pipelines

NOT INTENDED FOR:› New pipeline construction› Post emergency communications› Operator-specific performance addressed

through other means of communication

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Contains 8 sections related to various requirements› Sections are required parts of program› Are ENFORCEABLE

Five Appendices› Are NOT enforceable› Considered guidelines

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Section 1.3.11 clarifies the use of “may”versus “should”

May provides the operator with the option to incorporate the identified component into their program.

Should provides the operator with the components that are recommended to be incorporated into their component.

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The Federal regulations require operators to follow the baseline and supplementalrequirements of API’s “Public Awarenessprograms for Pipeline Operators” APIRecommended Practice 1162, First Edition, December 2003” (API RP 1162)unless the pipeline operator provides valid justification (see 192.616(c) and 195.440(c))

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To be valid, the justification must:› be written,› be based on a sound engineering and/or safety

analysis,› adequately explain why compliance with the

action is not practicable for the specific pipeline system,

› adequately explain why compliance with the action is unnecessary for safety on that specific pipeline system, and

› provide a level of safety equal to, or greater than, that which would be provided had the operator followed the action.

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API RP 1162 defines a 12-step process for program development› Overall Program Administration Steps 1 – 4

› Program Development Steps 5 – 12

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Define program objectives of public awareness› What program should accomplish› Tied to: public awareness and understanding prevention and response

Section 2.1 of API RP 1162

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Obtain management commitment and support of program› Includes participation, funding, and resources

to develop, implement and manage the program

Section 2.5 of API RP 1162

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Identify administrator, and define roles and responsibilities.› Key personnel involved› Company policies and procedures› Periodic review› Documentation and records

Section 7 of API RP 1162

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Identify assets in the program› Single program for all pipelines› Segmented by pipeline or facility› Multiple programs for different types of

pipelines› Single or different administrators

Section 7 of API RP 1162 Appendix B (non-enforceable)

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Identify the four stakeholder audiences› Affected Public Persons living/working near or adjacent to

pipelines or other facilities Customers Defined by operator

› Section 3.1 of API RP 1162 provides examples to be considered.

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Identify the four stakeholder audiences› Emergency Officials Officials, agencies or organizations with

emergency response or public safety jurisdiction

› Section 3.2 of API RP 1162 provides examples

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Identify the four stakeholder audiences› Local public officials Local, city, county, State officials with land

use or street jurisdiction along pipeline Not every public official

› Section 3.3 of API RP 1162 provides examples

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Identify the four stakeholder audiences› Excavators Companies, agencies or utilities involved in

any form of excavation activities Land developers One-call centers

› Section 3.4 of API RP 1162

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Determine the messages› Message will vary slightly according to the

audience and the type of operator› Message should include enough information

to convey basic content and meet objectivesas outlined in Section 2.2

› Recognize different messages for different stakeholders

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Tables give examples of message contentfor various stakeholders› Table 2-1 – Liquid and Gas Transmission› Table 2-2 – Gas Distribution› Table 2-3 – Regulated Gathering Systems

Pre – test materials (Section 8.4.2 of API RP 1162)› Effectiveness evaluation

Appendix C of API RP 1162(non-enforceable)

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All messages should include basic information:› Pipeline purpose and reliability(4.1)› Hazards and prevention (4.2)› One-Call and Damage Prevention (4.5)› Leak Identification (4.3)

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All messages should include basicinformation:› Emergency preparedness communications

(4.4)› Pipeline Location Information (4.6)› Integrity Management Information (4.7)› Web site content (4.8)› How to get additional information

Section 4 of API RP 1162

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Potential hazards of products should be specific to pipeline (4.3.1)

Pipeline marker information (4.6.1) Maps showing line size, product, and

approximate location of pipeline and availability of NPMS (4.6.2)

High consequence area (HCA) communications (4.7)

Security (4.11)

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RP 1162 talks about language in Appendix C

Language is a requirement from code, and not RP1162

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Establish frequencies› Minimum frequency specified in RP 1162

varies from 1 to 3 years according to type of pipeline and audience

› Tables 2 - 1, 2 - 2, and 2 – 3› May reduce frequencies, but that becomes

the standard to which operator is held

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Establish delivery methods for each message› Appropriate methods – primary or alternate

methods Printed material, personal contact, electronic or mass

media› Documentation of delivery and returns

Sections 2.8 and 5 of API RP 1162 for additional information.

Appendix D of API RP 1162(non-enforceable)

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Considerations for supplemental programenhancements› Supplemental activities are beyond

recommended baseline› Supplemental or enhancement› Do they use any supplemental activities?

Sections 2.8 and 6 of API RP 1162

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Section 6.2 of API RP 1162 provides 12 factors to consider for supplemental enhancements› Potential hazards› HCAs› Population density› Land development activity› Land farming activity› Environmental considerations

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Section 6.2 of API RP 1162 provides 12 factors to consider for supplemental enhancements› Third-party damage incidents› Pipeline history in an area› Specific local situations› Regulatory requirements› Results from previous PAP Evaluations› Other relevant needs

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Supplemental activities might include:› Larger audiences by expanding coverage

areas› More frequent contact or face-to-face contact› Enhanced mailings specific to a target

audience› Participation in local planning meetings› Educational efforts at schools, local fairs or

shows› Emergency drills with first responders

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Implement program and track changes› Identify personnel, budgets and vendors› Conduct program activities› Collect feedback and update program

Section 7 of API RP 1162

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Documentation and recordkeeping› Section 7.1 of API RP 1162 outlines information

that shall be included in written plan Management support statement Roles and responsibilities Identification of communication methods and

process of selection Stakeholder communication frequencies Program enhancements Evaluation process

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Documentation and recordkeeping› Section 7.2 of API RP 1162 lists some of the

records to be kept, including: Lists of stakeholders Samples of communications Program evaluations

› Minimum of 5 year retention

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Program evaluation› Establish evaluation processes› Self assessment of implementation Annually

› Program effectiveness Every 4 years

Section 8 and Table 8-1 of API RP 1162 Appendix E of API RP 1162(non-

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Assess results› Achieving objectives› Supplemental activities

Annual audit for implementation by:› Internal self assessments› Third-party audits› Regulatory inspections

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Effectiveness Evaluations› Every 4 years› Outreach› Understandability› Desired behaviors› Bottom line results

Company, third-party or industry surveys

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Continuous improvement› Changes to improve program› Documentation of changes› Funding or resource requirements› Implement changes

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Questions?

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