PHMSA Issues Advisory Bulletin Reminding Pipeline Operators of Federal Requirements on Emergency Preparedness Communications
By Susan Olenchuk, Jim Curry, Katie Leesman
November 12, 2010 -- On November 3, 2010, the Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin reminding gas and hazardous liquid pipeline operators that the federal pipeline safety regulations require that each operator maintain informed relationships with local emergency responders. In particular, pipeline operators must share their written emergency response plans with emergency responders. These written emergency response plans are required under the federal regulations and must contain provisions for coordinating preplanned drills with appropriate fire, police, and other public officials. PHMSA recommends that pipeline operators provide these emergency response plans to local emergency responders through the operator's required liaison and public awareness activities, including during joint emergency response drills.
The Advisory Bulletin warns operators that in future compliance inspections, PHMSA intends to evaluate the extent to which operators have provided their emergency response plans to local emergency responders. The Advisory Bulletin provides useful and important guidance on PHMSA's interpretation of emergency plan and public awareness regulations, and indicates 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.
Van Ness Feldman regularly counsels clients on issues related to pipeline construction, permitting, safety, and operation. Specifically, the firm has in-depth experience counseling clients on compliance with the Pipeline Safety Act and regulations. If you are interested in additional information regarding PHMSA's Advisory Bulletin, or any other energy-related federal activity, please contact Susan OlenchukJim Curry at (202) 298-1831, Jonathan Simon at (202) 298-1932, Mona Tandon at (202) 298-1836, or any member of the firm's Natural Gas or Oil and Products Pipeline practice groups.
at (202) 298-1896,