Pipeline Construction Impacted By OSHA Proposal on Crystalline Silica

October 2013, Vol. 68 No. 10

PHMSA considers elimination of class location rules on pipeline safety
Should the federal government ditch the long-standing class location system which allows pipelines to operate at reduced levels of stress based on population near the pipelines? That is one of the issues before the Pipeline and Hazardous Materials Safety Administration (PHMSA) which issued a proposed rule on this matter in August. The PHMSA didn't take a position on the question. But it was asking it because a provision in the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 requires the Secretary of Transportation to evaluate and issue a report on whether IMP requirements should be expanded beyond high consequence areas (HCAs) and whether such expansion would mitigate the need for class location requirements.

Class locations were an early method of differentiating risk along gas pipelines. The class location concept pre-dates Federal regulation of pipelines. These designations were previously included in the ASME International standard, “Gas Transmission and Distribution Pipeline Systems,” (ASME B31.8) from which the initial pipeline safety regulations were derived.

PHMSA previously published an extensive list of possible new pipeline safety regulations in August 2011. Those included strengthening and adding more prescriptive language to integrity management (IM) requirements and revising the definition of HCAs. At that time, the PHMSA acknowledged that it was raising "several important and complex public safety issues, many of which, if implemented, could impose significant cost on the pipeline industry."

PHMSA has not taken any new regulatory steps on pipeline safety since that August 2011 "advanced notice of proposed rulemaking." But this latest proposed rule could be considered an outgrowth since any elimination of the class location safety system might pave the way for needed changes to the definition of HCAs. The Interstate Natural Gas Association of American (INGAA) has opposed any regulatory redefining of HCAs, and has said it had voluntarily extended integrity management – i.e. pigging – way beyond HCAs, to 65 percent of the 300,000 miles of interstate pipe by the end of 2012. There are 18,000 miles of pipeline in HCAs.

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