DOT should update federal safety rules for LPG systems, report says

Sept. 10, 2018
US federal safety regulations for small distribution systems used for propane and other LPGs should be improved for clarity, efficiency, enforceability, and applicability to risk, the National Academies of Sciences, Engineering, and Medicine (NASEM) recommended in a Sept. 10 report.

US federal safety regulations for small distribution systems used for propane and other LPGs should be improved for clarity, efficiency, enforceability, and applicability to risk, the National Academies of Sciences, Engineering, and Medicine (NASEM) recommended in a Sept. 10 report.

Because states do not enforce compliance with the federal regulations consistently, there is little understanding of how the requirements affect the safety of LPG pipeline systems, particularly the smallest ones with fewer than 100 customers, it said.

The study noted that while most LPG systems consist of a storage tank and supply lines serving a single home or business, some systems are configured to deliver LPG to multiple homes or businesses.

When these multi-user systems serve 10 or more customers, or if they have two or more customers and part of the system is in a public place, they become subject to federal safety regulations administered by the US Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA), it noted.

The federal regulations, which are LPG-specific and apply to all LPG systems regardless of the number of customers, supplement National Fire Protection Association (NFPA) safety standards, the study said. In most cases, states enforce the federal regulations as well their own regulations and the NFPA codes, it added.

Congress requested study

NASEM said Congress asked for a study of whether the federal regulatory requirements, which also apply to large natural gas distribution systems, are appropriate for small LPG systems that must already comply with the NFPA codes.

It said that the committee that carried out the study and wrote the report reviewed records of pipeline incidents and found that serious incidents involving LPG distribution system are not frequent.

The committee also found evidence that many small multi-user LPG systems are not being inspected regularly for compliance with federal regulations, possibly due to inconsistent regulatory interpretations about when a system falls under the requirements and state regulators having limited resources to identify and inspect the smaller systems, NASEM said.

An apparent source of state-to-state enforcement variability is different interpretations by states and operators about what constitutes a “public place,” it added.

Without more complete information on the number, location, configuration, and condition of multi-user LPG systems, the committee said it would be a mistake to make changes to the safety regulatory framework based on simple criteria such as the number of customers on a system.

Recommended steps

It recommended that a series of steps be taken to better identify the location, condition, and risk characteristics of small multi-user systems, and to ensure that the regulatory requirements and their enforcement are appropriate to those risks.

The report also called on Congress to direct PHMSA to ensure the term “public place” is uniformly interpreted by regulators and LPG pipeline operators alike. The committee said that LPG pipeline system operators should also be required to report to regulators the location, number, and safety performance of their systems that fall under federal jurisdiction.

It said that once those systems have been identified and inspection activity confirmed by states, PHMSA should allow individual states to develop a waiver program allowing operators to opt out of federal requirements that the state has determined are not in line with the risk the operator’s system presents.

The report also noted that each state should be required to obtain PHMSA’s approval of its waiver program and have it periodically renewed by the federal pipeline safety agency.

Contact Nick Snow at [email protected].