Sharing Pipeline Emergency Response Plans

Today the Pipeline and Hazardous Material Administration (PHMSA) published an Advisory Bulletin in the Federal Register to “remind operators of gas and hazardous liquid pipeline facilities that they must make their pipeline emergency response plans available to local emergency response officials” (75 FR 67807). As I noted in an earlier blog one of the complaints from local responders after the San Bruno pipeline explosion was their lack of knowledge about the PG&E emergency response plan. While that incident is not mentioned in this Notice, it is almost certainly the reason that PHMSA is issuing this Advisory.

This is very carefully not a change in regulations, but more of an explanation of how PHMSA intends interpret the current regulations concerning the sharing of operator emergency response plans with local responders. The most important part of the actual Advisory Bulletin is contained in the last sentence:

“PHMSA intends to evaluate the extent to which operators have provided local emergency responders with their emergency plans when PHMSA performs future inspections for compliance with relevant requirements.”

This still doesn’t deal with the issue of producing effective emergency response plans that coordinate the notification and response of emergency personnel from both the operator and local emergency response agencies. Not that this is really PHMSA’s responsibility to effect that change; it will require significant legislative changes to the emergency response planning framework. Those changes will have to move the current weak emergency planning requirements beyond just the necessity of having an emergency response plan, to putting into place a mandated methodology for coordinating, reviewing, approving, and exercising such plans.