December 30, 1999

U.S. Department of Transportation (DOT)
Research and Special Programs Administration (RSPA)
Attn: DOT Dockets Office, Room POL-401
Docket #RSPA-99-6355
400 Seventh Street, SW
Plaza Room #401
Washington, DC 20590-0001


The purpose of this letter is to provide comment from the American Society of Safety Engineers (ASSE) addressing the RSPA 10/21 Federal Register request for comments on: Pipeline Safety, Enhanced Safety and Environmental Protection for Gas Transmission and Hazardous Liquid Pipelines in High Consequence Areas. To this end, we present the following:

The American Society of Safety Engineers (ASSE), is the oldest and largest Society of Safety Professionals in the world. Founded in 1911, ASSE represents almost 33,000 dedicated safety professionals. Included in this membership are Certified Safety Professionals, Professional Engineers, ergonomists, academicians, fire protection engineers, system safety experts, industrial hygienists, physicians, occupational nurses, and an impressive collection of other disciplines, skills, and backgrounds. We pride ourselves on our dedication to excellence, expertise, and commitment to the protection of people, property, and environment on a world?wide basis.

ASSE serves as Secretariat of seven (7) American National Standards Institute Committees (ANSI) developing safety and health standards which are used by private sector organizations as well as state/Federal governmental agencies such as MSHA, OSHA, etc... ASSE members also sit on over forty (40) additional standards development committees and the Society sponsors educational sessions on standards development. The Society also has eleven (11) technical divisions consisting of: Construction, Consultants, Engineering, Environmental, Health Care, International, Management, Public Sector, Risk Management and Insurance, Mining, and Transportation. The ASSE members included in these divisions are leaders in their field with the knowledge and expertise needed to move safety and health forward on a global level. We have also attached a fact sheet on the Society for your review, (Attachment #1).

Commentary Insights The intent of ASSE is not to speak either for or against the proposal, but rather to make comments based upon our member views, existing data, and anecdotal information. Based upon this collective insight, we submit the following:

Our first comment is to ask if the RSPA has considered working with the U.S. Chemical Safety and Hazard Investigation Board (CSB) on this issue. The CSB might have data, history, and expertise that be of value in addressing some of the technical issues discussed in the summary and background section of the proposal. Our suggestion is that RSPA should discuss this issue with CSB board members and staff to see if there can be a way to support each others efforts. It would also make sense for RSPA to work out a protocol for investigations with the CSB. The CSB has improved its synergy with other Federal issues, and this might be another which should be considered as well.

Our recommendation is that RSPA should continue to increase its outreach to local emergency response organizations and industry when addressing this issue. Local emergency response organizations and industry officials have significant experience and expertise to share. One area where they could specifically offer insight is in addressing hands-on training and competence for emergency response teams. We have found little guidance in standards/regulations specifying what competencies a hazardous materials response organization should be required to meet. ASSE members commented this is a significant issue for companies that contract for such initiatives. The concern is that while there is some guidance for the individual competence of responders, the issue of organizational requirements is not addressed. This might be an area RSPA should be interested in addressing.

We also note that RSPA is addressing safety related functions requiring high levels of technical knowledge and expertise. Perhaps RSPA should consider reviewing the level of professional safety competence required to perform some of these functions. If RSPA does choose to review the issue of competence, we point out that ASSE is the secretariat for the American National Standard, Z590 Criteria for Establishing Levels of Competence and Certification in the Safety Profession. When this draft standard is approved we suggest that the Agency consider using the standard as a model for evaluating professional development programs for safety and health professionals working with pipeline related issues. Finally, ASSE strongly supports the concept of recognizing accredited certification. We have included a packet of information on the Board of Certified Safety Professionals (BCSP) as an indicator of what constitutes a high caliber accredited certification.

ASSE also notes that RSPA dedicates little to any text indicating how the agency intends to work with voluntary national consensus standards development organizations like ANSI, ASTM, NFPA, etc… It would make sense for RSPA to review current voluntary national consensus standards and consider incorporating them by reference in future initiatives. OMB A-119 and Public Law 104-113 call for the increased utilization of voluntary national consensus standards. It would make sense to us to have some type of plan to accommodate the increased usage of voluntary national consensus standards. This is especially true since a review of the ANSI catalog indicates that there are many voluntary national consensus standards which could impact this initiative, (e.g.: ANSI/ASME B-30 Series, catalog listing attached).

We thank you for your attention to this matter, and look forward to working with you in the future. If you should have any questions or issues please do not hesitate to contact the Society.


Frank H. Perry, CSP, PE
Society President, 1999-2000

Copy To: ASSE Board of Directors
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