Duty to Warn and Propane Jurisdictional Systems
March 5, 2018
Sending an annual Duty to Warn mailing to customers is a simple way to reduce risk and protect your customers. But did you know that certain systems require Duty to Warn? These jurisdictional systems fall under federal and state regulations that propane marketers must meet.
1. What is a jurisdictional system?
A jurisdictional system is a propane system that serves multiple dwellings, buildings, or businesses. A system is jurisdictional if it falls under the description of any of the following:
- A system of pipes serving 10 or more customers by a single tank or propane service.
- A system of pipes serving two or more customers by a single tank or propane source within a public place. A public place is generally open to all persons in a community such as churches, schools, commercial buildings, and shopping malls.
- A single home tank where any portion of the system is located in a public place.
2. What about systems served by a master meter?
A master meter is a pipeline system for distributing gas typically found in condominium associations, mobile home parks, apartment complexes, or housing projects. Jurisdiction ends at the outlet swivel of the meter or the connection to the customer’s piping, whichever is further downstream.
3. What are the rules and regulations?
Relevant regulations are published in Title 49 of the Code of Federal Regulations (CFR). Special regulations for propane gas systems are contained in Parts 191 and 192 of 49 CFR. In addition to the rules of CFR, the propane industry is also governed by NFPA 58 and NFPA 59. Propane operators who install, deliver, and maintain equipment are required to follow these safety regulations. Jurisdictional system regulations have associated requirements that affect system installation, personnel training, system maintenance, and incident response.
4. Who establishes these safety regulations?
The federal government is primarily responsible for developing, issuing, and enforcing pipeline safety regulations. Many states have partnered with the federal government to provide enforcement through state agencies, who develop and implement additional regulations that are incorporated into their state’s Gas Safety Rules.
5. How does having a jurisdictional system affect Duty to Warn?
Propane companies that supply propane through jurisdictional systems are required to send Duty to Warn mailings to their customers every 6 months. This helps keep propane companies, customers, and surrounding public spaces safe. If you supply propane to a jurisdictional system, choose the P3 Duty to Warn Program to easily meet your requirement and receive additional benefits:
- Custom Branded Letters
- PERC Safety Information
- Discounted Pricing and Postage
- Third-Party Verification Certificate
- Secure File Transmission