This code section specifies the procedures that operators must implement in their Emergency Plan. Paragraph (a)(3) discusses response actions when operators are notified of emergency situations.
A long-standing discussion has revolved around what to tell people who call about gas leaks and odors inside a building. When do you tell them to leave? What actions should they take?
Many companies will ask a series questions as the caller interacts with the call center in an attempt to quickly determine if evacuations are necessary. These questions do not take more than a few seconds and are intended to help assess what additional response actions may be required beyond immediately dispatching a first responder. Often times callers may report hissing noises or construction that may indicate broken pipes requiring immediate evacuation from the area.
What do you tell someone when advising evacuation? How long do you want them to remain in a potentially hazardous location? Here’s a list of possible instructions:
Leave the area/building if hazard indicated
Do not create ignition sources (smoking, lights, flashlight)
Do not operate electrical appliances
Do not operate mechanical equipment
Don’t go back in the area to turn items off
Walk, don’t drive away
Are there additional instructions that should be given to callers? Is this sufficient to meet the intent of the regulation?
The following interpretation from 1997 addresses this issue.
Interpretation 192.615 9
June 17, 1997
U.S. Department of Transportation
Research and Special Programs Administration
400 Seventh Street, S.W.
Washington, DC 20590
Mr. Edward J. Ondak
Director, Western Regional Office
Office of Pipeline Safety
Suite A-250
12600 W. Colfax Avenue
Lakewood, CO 80215
Dear Mr. Ondak:
This responds to your letter of April 22, 1997, about emergency procedures under 49 CFR 192.615(a)(3)(I) for handling notices of gas detected inside buildings. You ask if we have an official position on what operators should tell someone who calls to report smelling gas inside a house. The question arises because some operators tell callers to leave the house immediately without first opening windows and doors. In contrast, the traditional response has been to tell callers to open all accessible windows and doors before exiting. In either case, the operator sends personnel to the site to investigate the report.
Section 192.615(a)(3)(I) allows operators latitude in responding to notices of gas odor inside buildings. As long as an operator’s response is “prompt” and is “effective” in minimizing the hazard, there would be little reason, if any, to challenge the appropriateness of the operator’s procedures. Given the pros and cons of taking time in a gas emergency to open windows and doors before exiting, we do not think there is sufficient reason to challenge the effectiveness of a response that tells callers to exit quickly without stopping to open windows and doors.
If you need additional information1 please contact me.
Sincerely,
Richard D. Huriaux
Director for Technology and Regulations
Office of Pipeline Safety
All this and more including interpretations and the history of regulations in WinDOT, The Pipeline Safety Encyclopedia.
The WinDOT Report 