Gas Notification Requirements: Are You Up to Speed?

September 2006

All gas operators should make sure they are well informed regarding federal and state notification requirements that must be followed in the event of an emergency. The following outlines those requirements.

Federal Requirements

All gas operators should be aware that the Office of Pipeline Safety (OPS) requires telephonic notice of gas incidents (49 CFR 191.5) within two hours of discovery. OPS has fined operators who were slow in reporting. Even though two hours may not be enough time to determine cause of an incident, operators are encouraged to place a call immediately to be on the safe side. It is common for telephone reports to be made of situations that are later found NOT to be reportable incidents. Reporting requirements to OPS can be viewed on the IAMU website, www.iamu.org (Click on “Gas” on the front page; then on the next page click on “Reporting Accidents”).

Telephonic reports are not taken by the Office of Pipeline Safety. Rather, they go to the National Response Center (NRC) at 800/424-8802, a “24/7” service operated by the Coast Guard that collects and forwards emergency and accident information for several agencies. If you later conclude that an event was not jurisdictional, a report to the NRC cannot be withdrawn. Instead, send a letter to the OPS for incident reports. Include in the letter the NRC report number, a brief description of the accident and why you concluded it was not reportable, and conclude saying that an incident report (Form RSPA F 7100.1) will not be filed.

A copy of the letter should also be sent to the Iowa Utilities Board (IUB rule 199 IAC 19.2(5)g). Be aware that the OPS address for incident reports has recently changed due to a reorganization within the US Department of Transportation. The current address (from 49 CFR 191.7) is:

Information Resources Manager
Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Room 7128
400 Seventh Street, SW
Washington DC 20590

Operators should also know that U.S. Postal Service mail goes through a security screening system at the U.S. Department of Transportation and may take ten days (or more) to be delivered to the intended office, and it has been reported that some items become lost. Consider using one of the private mail services. Their packages go straight to the intended offices.

It should also be noted that in the upper right hand corner of the incident report form there are “check-off boxes” indicating if it is an Original, Supplemental or Final Report. If an incident report is submitted, OPS considers the case “open” until a report marked “final” is received. Apparently there are numerous cases at any time still considered to be “open.” Make sure there is closure on any incident reports you have made by sending a “Final” report.

Completeness and accuracy of incident and annual reports is very important. If you are filling out one of these forms, be sure to read all instructions carefully. The forms and instructions are available on the Internet at ops.dot.gov/library/forms/forms.htm.

State Requirements

Like OPS, the Iowa Utilities Board (IUB) also requires telephonic notice of gas incidents (199 IAC 19.2(5)(b) within two hours of discovery, and operators have been cited for slow reporting. As with the federal requirements, you are urged to report any and all incidents, even if they are later found to not be reportable. IUB gas incident reporting requirements may be viewed on the IAMU website, www.iamu.org (Click on “Gas” on the front page; then on the next page click on “Reporting Accidents”).

Telephone reports during IUB offices hours should be made to 515/281-5546. To report emergencies during non-office hours, contact Don Stursma at 641/932-7071; if no answer, call his secondary number, 641/295-0895. In the event that all of the above numbers should fail, contact any of the IUB gas inspectors (gas operators should be sure to have these numbers on file).