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One of the Congressional mandates within the Protecting Our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020 was for the Pipeline and Hazardous Materials Safety Administration (PHMSA) to perform a study on natural gas distribution operators concerning Pipeline Safety Management Systems (PSMS). Congress asked PHMSA to determine:

1. The number of operators of natural gas distribution systems who have implemented PSMS in accordance with API RP 1173
2. The progress made by operators of natural gas distribution systems who have implemented, or are in the process of implementing PSMS; and
3. The feasibility of an operator of a natural gas distribution system implementing PSMS based on the size of the operator as measured by the number of customers the operator has and the amount of natural gas the operator transports.

PHMSA shared a first draft of the Information Collection Request that they will use to gather information from natural gas distribution operators. The data gathered through this form will ultimately be the basis for their report to Congress. At this time, PHMSA is only asking for public comment on the form and its instructions, not conclusions or recommendations. PHMSA will take APGA’s comments on the form into consideration before finalizing it and asking all distribution operators to complete it.

The APGA PSMS Task Group will provide a first draft of the comments for the full Operations & Safety Committee to review. APGA will also be working in collaboration with the Industry PSMS Task Group to develop industry-wide comments.

Read the PHMSA Voluntary Adoption of American Petroleum Institute Recommended Practice 1173 for Gas Distribution Systems.

Read the recent PHMSA notice in the Federal Registrar.

Comments are due to PHMSA on November 7, 2022.

For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-464-2742 or by email at ekurilla@apga.org.