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APGA Encourages Early Preparation for PHMSA Voluntary PSMS Survey

By Erin Kurilla posted 07-13-2023 11:59 AM

  
In the coming weeks, the Pipeline and Hazardous Materials Safety Administration (PHMSA) will request all natural gas distribution operators to complete a voluntary survey concerning Pipeline Safety Management Systems (PSMS). This survey will enable PHMSA to effectively prepare their response to a congressional mandate from the PIPES Act of 2020. The mandate instructed PHMSA to supply a study describing: the number of natural gas distribution systems that have voluntarily implemented PSMS in accordance with API Recommended Practice 1173 – Pipeline Safety Management Systems; the progress made by those systems in their implementation of API RP 1173; and, the feasibility of an operator to implement PSMS per API RP 1173 given the number of customers they serve and the amount of gas transported by the system. 
 
PHMSA has posted the questions and the instructions for operators to begin reviewing and preparing their answers. Operators are not yet being asked to respond. PHMSA is in the process of launching an online portal application for submissions. It will be linked to the same portal used for Annual Report submissions.
 
It is APGA’s opinion that, although voluntary (i.e., there is no regulation requiring responses), it is imperative that public gas systems demonstrate understanding of the survey questions and willingness to respond. Congress asked PHMSA to report back on the “feasibility of an operator to implement PSMS in accordance with 1173”. In order to provide concrete data concerning where the threshold exists between PSMS per API RP 1173 and the concepts that govern pipeline safety management systems principles, maximum industry participation in the survey will be needed.
 
APGA is hosting a webinar on August 15, 2023 at 2:00 PM ET to discuss the questions in the survey and provide further context for the need to participate. 
 
To view the form & instructions, please visit Pipeline Compliance Forms | PHMSA (dot.gov).
For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-905-2904 or by email at ekurilla@apga.org.

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