One of the most common issues I find when reviewing operator’s public awareness written plans is missing relevant factors for supplement messages to the baseline program. Operators sometimes believe that because the American Petroleum Institute RP 1162 (Public Awareness for Pipeline Operators) uses the language “should contain these relevant factors”, that it is optional. The reality is that when this standard was incorporated by reference (IBR) into pipelines safety code in 49 CFR Part 192 (gas) and 49 CFR Part 195 (hazardous liquids), the “Shoulds” in RP 1162 become “Shalls” that are required in each operator’s public awareness program.
During your next review of the your public awareness plan, look to see that all the relevant factors for supplemental messages are in your written plan and that all the “Shoulds” in RP 1162 are addressed as “Shalls” in your written program.
This month’s special: $195 to review your public awareness written program and identify any compliance issues you should address.*