NASFM Guidelines for the Fire Service
Identifying Sensitive Areas Along Natural Gas Transmission Pipelines
The Pipeline Safety Improvement Act of 2002 calls for increased standards for pipeline safety. As part of the law, pipeline operators are required to identify areas along their natural gas transmission lines where people are likely to congregate. Once they identify these "High Consequence Areas" - or HCAs - the operators must develop and implement a special safety management program for those pipeline segments. In many cases, these HCAs will be obvious, but other areas - like campgrounds, baseball fields and beaches - may be more difficult for pipeline operators to identify.

That's why pipeline operators are being urged to consult public safety officials, who typically have an in-depth understanding of the communities where they serve. This part of the rule potentially makes fire officials a source of information to natural gas pipeline operators. Because thousands of fire departments have pipelines passing through their jurisdiction, the National Association of State Fire Marshals has prepared this list of Frequently Asked Questions to help local fire officers respond to these types of requests from pipeline operators.

How is an "identified site" defined?
An HCA is an outside area or open structure that is:
  • occupied by 20 or more people on at least 50 days in any 12 month period, or
  • a building that is occupied by 20 or more people on at least 5 days a week or 10 weeks in any 12 month period, or
  • a facility occupied by people who are confined, are of impaired mobility or would be difficult to evacuate.

    • How can I be expected to keep track of how many people
    are at places of this type and how many days a year or week they are there?
    You can't, and there's no requirement that you do so. We encourage you to assist the pipeline operator by listing all the potential sites that you're aware of and to let the operator determine if those locations fall within the definition.

    Do I have a choice as to whether to respond to these requests from pipeline operators?
    Yes. The rule says that if a public safety official tells the operator that he or she cannot help identify these areas, the pipeline operator must then use other sources.


    Then why should we get involved?
    Because it is important to the safety of your communities and a key element of federal policy to make the pipeline infrastructure safer. NASFM endorses that goal and encourages all emergency responders to work with pipeline operators to achieve it. They need and will appreciate your help. Cooperating with them will let you know exactly where pipelines are in your jurisdiction and give you a better relationship with the operators who manage them.

    Is there a potential liability attached to a fire official for giving pipeline operators a list of
    identified sites? What if I give them a list of areas but overlook one or more?
    The possibility of liability exists in almost everything we do, but NASFM's legal counsel believes there are procedures that will virtually eliminate these concerns with the HCA program.

    What are those procedures?
    You should make sure that the request for information from the pipeline company is documented in writing, and the operator should acknowledge that the identification of these sites ultimately is the responsibility of the operator (see 49 CFR 192.905) and not the public safety official. Your response should also be documented in writing and make clear that the list includes only those sites known to you at the time the list was prepared, that the list is not necessarily all-inclusive, and in no way relieves the pipeline operator of the responsibility to identify all sites as defined in the rule. You should also encourage the operator to access other information sources (including information the operator obtains from routine operation and maintenance activities, local emergency planning committees, etc.) to help assure that all "identified sites" are identified.

    What if I become aware of new potential "identified sites" after the existing locations have been identified?
    The intent is for public safety officials and pipeline operators to have an on-going relationship. If you learn of a new site that may meet the definition of an "identified site," you should pass it along to the pipeline operator. The pipeline operator should also keep in contact with you and notify you of new pipeline projects.

    We don't know if we have pipelines in our jurisdiction, much less where they are
    located. We have no specific training program on pipeline safety.
    It is entirely possible that pipelines exist in your community without your knowledge. Some were installed more than 40 years ago. If pipeline operators ask for your assistance in identifying sites, they must tell you where the pipelines and the HCAs are located. A training program on responding to pipeline incidents has been developed by the National Association of State Fire Marshals and will be available to fire departments nationwide this Fall.


    Other Resources
    1. Text of 49 CFR §192.905 from the U.S. Code of Federal Regulations
  • 192.905 How does an operator identify a high consequence area?
    •
    (a) General. To determine which segments of an operator's transmission pipeline system are covered by this subpart, an operator must identify the high consequence areas. An operator must use method (1) or (2) from the definition in §192.903 to identify a high consequence area. An operator may apply one method to its entire pipeline system, or an operator may apply one method to individual portions of the pipeline system. An operator must describe in its integrity management [program which method it is applying to each portion of the operator's pipeline system. The description must include the potential impact radius when utilized to establish a high consequence area. (See appendix E.I. for guidance on identifying high consequence areas.)
    (b)(1) Identified sites. An operator must identify an identified site, for purposes of this subpart, from information the operator has obtained from routine operation and maintenance activities and from public officials with safety or emergency response or planning responsibilities who indicate to the operator that they know of locations that meet the identified site criteria. These public officials could include officials on a local emergency planning commission or relevant Native American tribal officials.
    (2) If a public official with safety or emergency response or planning responsibilities informs an operator that it does not have the information to identify an identified site, the operator must use one of the following sources, as appropriate, to identify these sites.
    (i) Visible marking (e.g., a sign); or
    (ii) The site is licensed or registered by a Federal, State, or local government agency; or
    (iii) The site is on a list (including a list on an internet web site) or map maintained by or available from a Federal, State, or local government agency and available to the general public.
    (c) Newly identified areas. When an operator has information that the area around a pipeline segment not previously identified as a high consequence area could satisfy any of the definitions in §192.903, the operator must complete the evaluation using method (1) or (2). If the segment is determined to meet the definition as a high consequence area, it must be incorporated into the operator's baseline assessment plan as a high consequence area within one year from the date the area is identified.

    2. Text of 49 CFR §192.903 (definition of "Identified Site") from the U.S. Code of Federal Regulations

  • 192.903 What definitions apply to this subpart?

    •
    Identified Site means each of the following areas:

    (a) An outside area or open structure that is occupied by twenty (20) or more persons on at least 50 days in any twelve (12)-month period. (The days need not be consecutive). Examples include, but are not limited to, beaches, playgrounds recreational facilities, camping grounds, outdoor theaters, stadiums, recreational areas near a body of water, or areas outside a rural building such as a religious facility; or

    (b) A building that is occupied by twenty (20) or more persons on at least five (5) days a week for ten (10) weeks in any twelve (12)-month period. (The days and weeks need not be consecutive). Examples include, but are not limited to, religious facilities, office buildings, community centers, general stores, 4-H facilities, or roller skating rinks; or

    (c) A facility occupied by persons who are confined, are of impaired mobility, or would be difficult to evacuate. Examples include but are not limited to hospitals, prisons, schools, day-care facilities, retirement facilities, or assisted-living facilities.
    3. Final Rule, 49 CFR Part 192, Pipeline Safety: Pipeline Integrity Management in High Consequence Areas (Gas Transmission Pipelines) published in the December 15, 2003 issue of the Federal Register, pages 69778 to 69837.

    4. DOT/RSPA Advisory Bulletin ADB-03-03 published in the July 17, 2003 issue of the Federal Register, page 42458.

    Further information on the HCA rule can be found at http://ops.dot.gov/