One of my common findings when inspecting public awareness plans was a lack of specificity regarding other language parameters in the operator’s public awareness plan. Specifically:
- Not specifying a percentage of the affected public audience speaking a foreign language at which messages will be sent in that language. Operators that did specify that percentage used ranges for 4% to 15%. Be able to justify what percentage you choose. Note in the code below, a percentage is not specified but rather other languages understood by a significant number of the affected public. This allows you as the operator to define what a significant number is for your public awareness program. Just be able to justify the percentage you choose. Note that rather than affected public the code uses the population in the operator’s area. For distribution operators there may be little distinction. For gas transmission and hazardous liquid operators, there may be a distinction when the affected public is small. Incorporated by reference (IBR) API RP 1162 clarifies this (see far below) by stating significant concentration of non-English speaking population along the pipeline which is basically the affected public audience.
- Not specifying the frequency with which the affected public will be resurveyed for changes in people speaking foreign language. For example, if you use census data that is only done every 10 years. If you use a private data source, pick a frequency that matches their resurvey frequency. Using 10 years for census data may be too long and alternate sources should be considered.
- The following GPTC Guidance may help determine what languages to consider:
- LANGUAGE
- The following may provide indications of languages in addition to English to consider when conducting public education programs.
- (a) Languages prescribed by state or local governments.
- (b) Commercial non-English radio, television, and print media.
- (c) U.S. Census data.
- 92.616 Public Awareness.
(g) The program must be conducted in English and in other languages commonly understood by a significant number and concentration of the non-English speaking population in the operator’s area.
- 195.440 Public Awareness
(g) The program must be conducted in English and in other languages commonly understood by a significant number and concentration of the non-English speaking population in the operator’s area.
API RP 1162
2.3.1
Public Education
(49 CFR Parts 192.616 and 195.440):
These regulations require pipeline operators to establish continuing education programs to enable the public, appropriate government organizations, and persons engaged in excavation-related activities to recognize a pipeline emergency and to report it to the operator and/or the fire, police, or other appropriate public officials. The programs are to be provided in both English and in other languages commonly used by a significant concentration of non-English speaking population along the pipeline.
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