PHMSA GD-SMS-2022 Voluntary Adoption of API RP 1173 for Gas Distribution S

OMB No: 2137-TBD
Expiration Date TBD
DOT USE ONLY
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration

Voluntary Adoption of American Petroleum
Institute Recommended Practice 1173 for Gas
Distribution Systems

Initial Date Submitted
Report Submission Type
Date Submitted

A federal agency may not conduct or sponsor, and a person is not required to respond to, nor shall a person be subject to a penalty for failure to
comply with a collection of information subject to the requirements of the Paperwork Reduction Act unless that collection of information displays

a current valid OMB Control Number. The OMB Control Number for this information collection is 2137-XXXX. Public reporting for this
collection of information is estimated to be approximately 3 hour per response, including the time for reviewing instructions, gathering the data
needed, and completing and reviewing the collection of information. All responses to this collection of information are mandatory. Send
comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to:
Information Collection Clearance Officer, PHMSA, Office of Pipeline Safety (PHP-30) 1200 New Jersey Avenue, SE, Washington, D.C. 20590.

Important: Please read the separate instructions for completing this form before you begin. They clarify
the information requested and provide specific examples. If you do not have a copy of the instructions,
you can obtain one from https://www.phmsa.dot.gov/forms/pipeline-compliance-forms.
1.

Operator’s OPS-Issued Operator Identification Number (OPID) ___________

2.

Name of Operator ___________

3.

Number of Customers Served by the Operator ___________

4. Amount of Gas Transported by the operator during Calendar Year 2022 in Thousands of Standard
Cubic Feet ___________
5. Do you have procedures, processes, or programs in place to address? (select all that apply)
____ a. Promoting a positive safety culture
____ b. Communicating and educating employees, contractors, and/or the public regarding pipeline
safety
____ c. Reducing risk and maintaining integrity to your pipeline assets
____ d. Developing and maintaining safe work practices.
____ e. Investigating incidents and near-misses on your pipeline system to identify and implement
corrective actions
____ f. Verifying existing operations and safety practices are improving pipeline safety
____ g. Reviewing your safety performance to determine if additional actions are necessary to improve
pipeline safety
____ h. Responding effectively to pipeline incidents
____ i. Assuring personnel are competent in tasks that impact the integrity of your system
____ j. Maintaining documentation needed to ensure pipeline safety
6. Has your company or system’s leadership demonstrated a tangible commitment to the
implementation of a pipeline safety management system (PSMS)?
Yes ____
No ___
7.

How did you become aware of RP 1173? (select all that apply)
Internal staff
Industry Affiliate
State regulator
Federal regulator
Not aware of RP 1173
Other (specify, up to 100 characters)

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8. Have you performed a gap assessment or other comparable exercise to compare your pipeline
safety and safety culture efforts to the concepts of safety management systems described in API RP
1173?
Yes ____
No ___
9. What barriers are preventing you from implementing an SMS program per API RP 1173 or other
SMS? (select all that apply)
____ Size of company
____ Limited Staff
____ Financial Considerations
____ Unfamiliar with SMS principles
____ N/A
____ Other (specify, up to 100 characters) _______________________________________
10.
What is the timeframe for closing initially identified gaps or addressing improvement opportunities?
(select only one)
____ a. current year
____ b. next year to 2 years
____ c. more than 2 years to 5 years
____ d. more than 5 years to 10 years
____ e. more than 10 years
____ f. no plan
11.
Is the implementation of your PSMS: (select only one)
______ a. on track with the plan
______ b. slower than planned
______ c. faster than planned
______ d. stalled for the moment
12.
What element(s) are you currently focused on for implementation? (select all that apply)
______ a. Leadership and Management Commitment
______ b. Stakeholder Engagement
______ c. Risk Management
______ d. Operational Controls
______ e. Incident Investigation, Evaluation, and Lessons Learned
______ f. Safety Assurance
______ g. Management Review and Continuous Improvement
______ h. Emergency Preparedness and Response
______ i. Competence, Awareness, and Training
______ j. Documentation and Record Keeping
______ k. Other (specify, up to 100 characters) _________________________________
13.
What elements have been the most challenging to implement? (select all that apply):
______ a) Leadership and Management Commitment
______ b) Stakeholder Engagement
______ c) Risk Management
______ d) Operational Controls
______ e) Incident Investigation, Evaluation, and Lessons Learned
______ f) Safety Assurance
______ g) Management Review and Continuous Improvement
______ h) Emergency Preparedness and Response
______ i) Competence, Awareness, and Training
______ j) Documentation and Record Keeping
______ k) Other (specify, up to 100 characters) __________________________

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14.
Have you conducted a review of your PSMS program?
Yes ____
No___
15.

If you answered “Yes” in #14, by whom? (select all that apply)
Internal staff
Independent third-party evaluator
State regulator
Federal regulator
Other (specify, up to 100 characters)

16.
Are you maintaining a method to evaluate PSMS maturity?
Yes ____
No ___
Preparer Name:
Preparer’s E-Mail Address:
Preparer’s Phone Number:
Authorized Person Name:
Authorized Person’s E-Mail Address:
Authorized Person’s Phone Number:

Form PHMSA GD-SMS-2022

Reproduction of this form is permitted

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Instructions for completing Form PHMSA GD-SMS-2022
Voluntary Adoption of American Petroleum Institute Recommended Practice 1173
for Gas Distribution Systems
If you need copies of the Form PHMSA F7100.5 and/or these instructions, you can obtain one from
https://www.phmsa.dot.gov/forms/pipeline-compliance-forms.
Each operator of a gas distribution system required to submit a Gas Distribution Annual Report, Form
PHMSA F7100.1-1, is requested to submit Form PHMSA GD-SMS-2022. As this is a one-time
information collection PHMSA is requesting only basic safety management system (SMS) implementation
information.
Form PHMSA GD-SMS-2022 and these instructions can be found on
https://www.phmsa.dot.gov/forms/pipeline-compliance-forms. The applicable documents are listed in the
section titled “GD-SMS-2022 Reporting Form”.
ONLINE REPORTING REQUIREMENTS
Reports must be submitted online through the PHMSA Portal at https://portal.phmsa.dot.gov/portal. Use
the following procedure for online reporting:
1.

Go to the PHMSA Portal at https://portal.phmsa.dot.gov/portal

2.

Enter PHMSA Portal Username and Password; press enter

3.

Select OPID; press “continue” button

4.

In the main panel, select the tab named “GD SMS”

5.

Select the link named “Create Report” and proceed with entering your data.

6.
Click “Submit” when finished with your data entry to have your report uploaded to PHMSA’s
database as an official submission or click “Save” which doesn’t submit the report to PHMSA but stores it
in a draft status to allow you to come back to complete your data entry and submit at a later time. Your
draft report is available at the link named “Saved Report” on the “GD SMS” tab.
If your submitted report needs to be corrected, you can submit a supplemental report. On the “GD SMS”
tab, click on the “Submitted Report” link and then click on Create Supplemental.
SPECIAL INSTRUCTIONS
All applicable data fields must be completed before you can submit the report.

1.

An entry should be made in each applicable space or check box.

2. If OTHER is checked for any answer to a question, include an explanation or description in the text
field provided, making it clear why “Other” was the necessary selection.
3.
a.
b.

Pay close attention to each question for the phrase:
(Select all that apply)
(Select only one)
If the phrase is not provided for a given question, then “select only one” applies. “Select only one” means
that you should select the single, primary, or most applicable answer. DO NOT SELECT MORE
ANSWERS THAN REQUESTED. “Select all that apply” requires that all applicable answers (one or more
than one) be selected.

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Instructions for completing Form PHMSA GD-SMS-2022
Voluntary Adoption of American Petroleum Institute Recommended Practice 1173
for Gas Distribution Systems
SPECIFIC INSTRUCTIONS
1. Operator’s OPS-Issued Operator Identification Number (OPID)
The OPID will automatically populate based on the selection you made when entering the PHMSA Portal.
If you have log-in credentials for multiple OPID, be sure the report is being created for the appropriate
OPID. Contact PHMSA’s Information Resources Manager at 202-366-8075 if you need assistance with an
OPID. Business hours are 8:30 AM to 5:00 PM Eastern Time.
2. Name of Operator
The name will automatically populate based on the OPID entered in 1. If the name that appears is not
correct, you need to submit an Operator Name Change (Type A) National Registry Notification.
3. Number of Customers Served by the Operator
This is the number of meters through which the operator sells gas.
4. Amount of Gas Transported by the operator in Calendar Year (CY) 2022 in Thousands of Standard
Cubic Feet
This is the amount of gas transported by the operator in CY 2022 in Thousands of Standard Cubic Feet.
5. Do you have procedures, processes, or programs in place to address? (select all that apply)
The question includes the terms procedures, processes, or programs to provide flexibility. In other words,
an operator may have a general program in place, but not necessarily a procedure or vice versa. API RP
1173 leans towards a procedure such as through the following language “At the operator level, these
elements may not appear distinctly in a single document but should be identifiable in a clear and
mandated process within the operator’s procedures.” However, other SMS approaches may not
specifically call for a procedure.
6. Has your company or system’s leadership demonstrated a tangible commitment to the implementation
of a pipeline safety management system (PSMS)?
Examples of tangible commitments include: a commitment statement from leadership, an assignment of
PSMS responsibilities to an employee, the dedication of resources, or the hiring of a PSMS consultant.
8. Have you performed a gap assessment or other comparable exercise to compare your pipeline safety
and safety culture efforts to the concepts of safety management systems described in API RP 1173?
Check “Yes” if you performed a gap assessment consistent with API 1173, even if you aren’t using API
RP1173 specifically. If you did not perform a gap assessment, check “No”.
9. What barriers are preventing you from implementing an SMS program per API RP 1173 or other SMS?
(select all that apply)
This question is intended to understand barriers and challenges to implement an SMS whether you
performed an initial gap assessment or are choosing not to implement (start) an SMS at this time.
Answers to this question will likely help provide input on the number of companies implementing a
pipeline SMS and the feasibility of an operator of a natural gas distribution company to implement a
pipeline SMS in line with the PIPES Act 2020 Section 205 language.
N/A means not applicable. In other words, you are in the process of implementing SMS.

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Instructions for completing Form PHMSA GD-SMS-2022
Voluntary Adoption of American Petroleum Institute Recommended Practice 1173
for Gas Distribution Systems
Select Other and provide comments if there are other challenges not on the list or you want to provide
additional information related to the question.
10. What is the timeframe for closing initially identified gaps or addressing improvement opportunities?
“Current year” means that you either have already addressed initially identified gas or opportunities or you
will have all initially identified gas or opportunities addressed within the current year. Check “no plan”
only if you have no plans to address the identified gaps or opportunities or are not planning to implement
an SMS in general.
11. Is the implementation of your PSMS: (select only one)
Choose “stalled for the moment” if your implementation is currently stalled or you are not implementing
SMS.
13. What elements have been the most challenging to implement? (select all that apply)
If your company is challenged by a specific element of PSMS and categorizes the elements differently
than the RP, please select “Other” and describe the element(s) your company is currently challenged by
in the text field.
16. Are you maintaining a method to evaluate PSMS maturity?
For a description of the PSMS maturity model, see https://pipelinesms.org/pipeline-sms-maturity-model/
PREPARER
The Preparer is the person who compiled the data and prepared the responses to the report and who is to
be contacted for more information (preferably the person most knowledgeable about the information in
the report or who knows how to contact the person or persons most knowledgeable). Enter the Preparer’s
e- mail address and the phone number of the Preparer.
AUTHORIZED PERSON
The Authorized Person is responsible for assuring the accuracy and completeness of the reported data.
In addition to their name, include a phone number and email address.

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