Pipeline Safety & CUPA
Where Safety Fuels Progress
About the Pipeline Safety & CUPA Division
The Office of the State Fire Marshal (OSFM) currently regulates the safety of intrastate hazardous liquid pipeline in California. OSFM Pipeline Safety Division staff inspect pipeline operators to ensure compliance with federal and state pipeline safety laws and regulations, and consist of engineers, Geographical Information System (GIS)/mapping staff, analytical staff, and clerical support located throughout California.
The OSFM is granted exclusive safety regulatory and enforcement authority over intrastate hazardous liquid pipelines in California through certification by the United States Department of Transportation (USDOT), Pipeline Hazardous Materials Safety Administration (PHMSA). Hazardous liquid pipelines can carry commodities such as crude oil, gasoline, propane, and other types of hydrocarbons. An intrastate hazardous liquid pipeline is a pipeline that is located entirely within the borders of the State of California, including offshore state waters. USDOT PHMSA maintains exclusive federal authority over interstate pipeline, which is a pipeline that crosses state borders or begins in federal waters.
USDOT PHMSA grants the OSFM exclusive regulatory authority over intrastate hazardous liquid pipelines. These California State Agencies are responsible for the following aspects of petroleum production:
- The California Geologic Energy Management Division (CalGEM) regulates oil and natural gas production pipelines and wells
- The State Lands Commission manages offshore oil and production within three miles of the coast.
- The California Public Utilities Commission holds jurisdiction over intrastate natural gas and liquid petroleum gas pipelines within California. (PHMSA inspects interstate natural gas and liquid petroleum gas pipelines, as well.)
Additional authority was provided to OSFM by statute in 1981 when the California Legislature passed the Hazardous Liquid Pipeline Safety Act which enacted the OSFM’s authority over intrastate hazardous liquid pipelines in California.
OSFM conducts six different types of inspections on pipeline operators and two different types of inspections on each pipeline system every five years. These inspections focus on specific sections of federal pipeline safety regulations and consist of a thorough record inspection, a procedure review, and a pipeline system field inspection component. In addition to the required inspections, OSFM must also respond to intrastate pipeline accidents, investigate significant intrastate pipeline releases, inspect pipeline construction and relocation projects, respond to train derailments near pipelines, and meet with state and local governments to discuss various pipeline safety issues.
The pipeline operator inspections are listed below and are required at least every five years. Each inspection can take anywhere from one week for smaller operators to 12 days for larger operators. Inspection length depends on many factors, such as: company size, how many miles of pipeline, the complexity of the pipeline system, and the location of the pipelines.
- Control Room Management (CRM) Program and Site – evaluates the operator’s safety procedures for controllers, control rooms, and Supervisory Control and Data Acquisition (SCADA) systems used to remotely monitor and control pipeline operations.
- Operator Qualification Program – reviews an operator’s plan and records to ensure that employees performing safety-sensitive tasks have the knowledge, skills and abilities needed to safely perform each task, as well as to recognize and react to unsafe conditions.
- Integrity Management Program – inspection of the operator’s written Integrity Management Plan and associated records to confirm that the operator can identify, prioritize, assess, evaluate, repair, and validate the integrity of their hazardous liquid pipelines.
- Operations, Management and Emergency (OM&E) Program – reviews an operator’s OM&E Manual to confirm that it meets state and federal requirements.
- Public Awareness and Public Education (PAPE) Program – reviews an operator’s PAPE to ensure that it meets requirements for public education of pipeline information including required components such as specific guidelines on audiences, messages, and frequency of messages.
- Drug and Alcohol Program – evaluates an operator’s anti-drug and alcohol misuse prevention plans and programs applicable to persons who operate, maintain, or conduct emergency-response functions.
Each inspection focuses on a part of a pipeline operator’s operation or on a pipeline system’s operation. A general high-level overview of inspection activities includes:
- Records review
- Procedure, policy and manual review
- Employee Records review
- Headquarters (HQ) site visit (CRM)
- Training Record and Time Sheet Review
- Investigation review of accidents
- Review of reported information data to OSFM and PHMSA
- Employee Testing (i.e., drug and alcohol, training, certifications, and refreshers)
Additionally, the OSFM does local inspections to verify data provided from the HQ and to verify if local sites are following HQ policy and documentation requirements.
The two types of pipeline system inspections are:
- Standard Main – this inspection is a field examination that focuses on the actual condition of the pipeline and the operational conditions at the worksite. These inspections ensure that the above program inspections are accurate and that procedures are followed on site.
- Local Field Verification of Individual Pipelines – California Chapter 607, Statues of 2015 (SB 295) mandates that OSFM inspects them every year. OSFM incorporates questions required under PHMSA five year inspections. After all questions are complete, data from all year’s questions are compiled to meet federal inspection mandates.
Note: The OSFM conducts additional inspections for the above topics during the year as procedures change. Additionally, the OSFM monitors hydrostatic testing and/or in-line inspection of pipelines. OSFM verifies that proper documentation occurs and that operations meet the goal of regulatory code.
The May 2015 pipeline incident at Refugio Beach in Santa Barbara County spilled over 100,000 gallons of crude oil into the Pacific Ocean and impacted over 25 miles of coastline. The impacts from the spill were devastating, both environmentally and economically. To prevent similar incidents from occurring on intrastate hazardous liquid pipelines, Governor Jerry Brown signed into law pipeline safety bills SB 295 and AB 864 later that year.
SB 295 required, among other things, the OSFM to annually inspect all intrastate pipelines and operators of intrastate pipelines under its jurisdiction and required the State Fire Marshal to adopt regulations required to implement these requirements. Regulations pursuant to SB 295 have been fully implemented.AB 864 required that any new or replacement pipeline near environmentally and ecologically sensitive areas (EESA) in the coastal zone to use best available technologies to reduce the amount of oil released in an oil spill to protect state waters and wildlife. Additionally, it required that an operator of an existing pipeline near these sensitive areas submit a plan to retrofit the pipeline to the OSFM. Finally, OSFM was required to develop regulations pursuant to these requirements by July 1, 2017.
Additional Pipeline & CUPA Information
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- Call Before You Dig: 811 is the national call-before-you-dig phone number. Please visit California's 811 resources before digging.
- California Underground Facilities Safe Excavation Board: The California Underground Facilities Safe Excavation Board investigates accidents, develops excavation safety standards and coordinates education and outreach programs, ensuring the state's safe excavation laws are followed. Please visit their website here for more information.
- Excavation Damage Data: PHMSA Excavation Damage Database
- FAQ - Control Room Management
- The Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued a signed interpretation letter dated December 4, 2019 clarifies the PHMSA Drug and Alcohol Testing regulations in 49 Code of Federal Regulations (CFR) Part 199.
- PI-20-0015 Interpretation of 49 CFR 195.454
- Other PHMSA Interpretation Letters are also available for review
Danger of Flood Damage to Pipelines:
State Law requires Pipeline Operators to notify the Office of the State Fire Marshal, Pipeline Safety Division of certain activities or changes in operations.
Starting December 2018, pipeline operators may send certain required notifications or requests to OSFM by email to PipelineNotification@fire.ca.gov.
Public records in the possession of the Department of Forestry and Fire Protection which are not exempt from disclosure under the Public Records Act (CGC section 6250) shall be available for inspection, and copies of such public records shall be provided, pursuant to these guidelines.
Visit the CAL FIRE Pubic Records Center at GovQA to request access to inspection records or to submit any other Public Record Act request.
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