Chemical Safety: Status of Changes to the National Fire 	 
Protection Association Code for Propane (06-JUL-01, GAO-01-709). 
								 
Liquefied petroleum gas (propane) has thousands of applications  
in homes, farms, and workplaces and is widely available in the	 
United States. While propane can be stored and handled safely,	 
serious propane-related accidents have resulted in loss of life  
and property. At times, the efforts of local emergency personnel 
to respond to such accidents have been impeded by lack of hazard 
and safety information. This report describes (1) relevant	 
revisions to the 1998 version of the code that were published in 
the 2001 version, as well as the process used to revise the code,
(2) the views of key stakeholders about whether the 2001 version 
of the code provides local emergency response personnel with	 
sufficient information to prepare for and respond to emergencies 
involving propane, and (3) the status of state and local	 
government adoption of the 2001 code. The 2001 version of the	 
NFPA code strengthens provisions of previous versions regarding  
information on the off-site effects of accidental propane	 
releases. And according to the nine key stakeholders interviewed 
by GAO, the 2001 version of the code would make available more	 
information to local emergency response personnel. All but one of
the stakeholders stated that additional changes to the code or	 
the process for revising the code may be needed. Finally, GAO was
not able to determine comprehensively the status of state and	 
local government adoption of the 2001 version of the code because
the code may be adopted in several ways.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-709 					        
    ACCNO:   A01153						        
  TITLE:     Chemical Safety: Status of Changes to the National Fire  
             Protection Association Code for Propane                          
     DATE:   07/06/2001 
  SUBJECT:   Accidents						 
	     Petroleum products 				 
	     Safety standards					 
	     Emergency preparedness				 

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GAO-01-709
     
Report to Congressional Committees

United States General Accounting Office

GAO

July 2001 CHEMICAL SAFETY Status of Changes to the National Fire Protection
Association Code for Propane

GAO- 01- 709

Page i GAO- 01- 709 Changes to the NFPA Code for Propane Letter 1

Results in Brief 3 Revised Code Strengthens Previous Provisions 5
Stakeholders Said the New Code Makes Available More

Information to Emergency Personnel, but Many Saw Need for More Changes 7
Definitively Determining the Status of the Adoption of the Code

Would Require Searching Laws and Regulations of States and Municipalities 9
Agency Comments 10

Appendix I Contents of the NFPA Liquefied Petroleum Gas Code and the Code
Revision Process 11

Appendix II Scope and Methodology 15

Table

Table 1: NPGA Information on the Number and Percentage of States That Had
Adopted Various Versions of the NFPA Liquefied Petroleum Gas Code as of
April 16, 2001 9 Contents

Page 1 GAO- 01- 709 Changes to the NFPA Code for Propane

July 6, 2001 The Honorable Harry Reid Chairman The Honorable Robert C. Smith
Ranking Minority Member Committee on Environment and Public Works United
States Senate

The Honorable W. J. ?Billy? Tauzin Chairman The Honorable John D. Dingell
Ranking Minority Member Committee on Energy and Commerce House of
Representatives

Liquefied petroleum gas (propane) has thousands of applications in homes,
farms, and workplaces and is widely available in the United States. While
propane can be stored and handled safely, serious propane- related accidents
have resulted in loss of life and property. At times, the efforts of local
emergency personnel to respond to such accidents have been impeded by lack
of hazard and safety information. The Clean Air Act Amendments of 1990
addressed the prevention of such accidents and the provision of information
to emergency response personnel. 1 The amendments required the Environmental
Protection Agency (EPA) to list at least 100 substances that, if
accidentally released into the environment, would pose the greatest risk of
causing death, injury, or serious adverse effects to human health or the
environment. Under the amendments, facilities handling quantities of any of
these substances above certain threshold amounts are required to develop and
submit a risk management plan to EPA. Risk management plans are to include
(1) a hazard assessment that includes a 5- year accident history by
substance by site and an evaluation of worst- case accidental releases; (2)
a prevention program that includes safety precautions and maintenance,
monitoring, and employee training measures; and (3) a response program that
includes emergency health care, employee training measures, and procedures
for informing the public and local agencies responsible for responding to

1 P. L. 101- 549, 104 Stat. 2399, sec. 112( r) (codified at 42 U. S. C.
7412( r)).

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 01- 709 Changes to the NFPA Code for Propane

accidental releases. In 1994, EPA issued the list of substances, which
included propane.

The National Propane Gas Association (NPGA) 2 subsequently objected to the
placement of propane on the list and told the Congress that sufficient
voluntary safety standards for propane already existed in the Code for
Liquefied Petroleum Gas, published by the National Fire Protection
Association (NFPA). 3 NFPA?s code, which has existed since 1940, is the
primary standard used in the United States for propane safety. The code has
been revised numerous times to reflect changes in the industry; in the past
decade, it has generally been updated every 3 years. States and
municipalities may choose to adopt the code into law. In April 2001, NFPA
published the 2001 version of the code.

In 1999, the Chemical Safety Information, Site Security and Fuels Regulatory
Relief Act 4 resulted in exemption for most propane facilities from the
requirement to submit risk management plans to EPA. 5 The act mandated that
GAO report, within 2 years, on the status of revisions to the NFPA code
regarding information for emergency personnel about the potential effects of
accidental releases of propane to surrounding areas (off- site effects). As
agreed with your offices, this report describes (1) relevant revisions to
the 1998 version of the code that were published in the 2001 version, as
well as the process used to revise the code; (2) the views of key
stakeholders about whether the 2001 version of the code provides local
emergency response personnel with sufficient information

2 NPGA is the national trade association for the propane gas industry. It
represents approximately 3,500 companies involved in the industry worldwide,
including producers, wholesalers, transporters, and retailers of propane
gas, as well as manufacturers and distributors of associated appliances and
equipment.

3 NFPA, an independent nonprofit organization, sponsors a technical
committee composed of representatives from the government, the propane
industry, educational institutions, insurance companies, fire associations,
and other organizations to review the code and develop by consensus any
revisions it believes are needed.

4 P. L. 106- 40, 113 Stat. 207 (1999). 5 The act prohibited EPA from listing
a flammable substance used as a fuel or held for sale as a fuel at a retail
facility solely because of its explosive or flammable properties, unless a
fire or explosion caused by the substance would result in acute adverse
health effects from human exposure to the substance. As a result, EPA
created a regulatory exclusion for propane when used as a fuel or held for
sale at a retail facility. But propane remains on the list when used for
other purposes.

Page 3 GAO- 01- 709 Changes to the NFPA Code for Propane

to prepare for and respond to emergencies involving propane; and (3) the
status of state and local government adoption of the 2001 code.

The 2001 version of the NFPA code strengthens provisions of previous
versions regarding information on the off- site effects of accidental
propane releases in four ways. First, the 2001 version of the code provides
that facilities? fire safety planning should include consideration of the
safety of emergency personnel, workers, and the public. The 1998 version
provided for consideration of the safety of only emergency personnel.
Second, the revised code provides that facilities with more than 4,000
gallons of propane on site evaluate their potential fire hazards and safety
procedures and document them in a written fire safety analysis. While the
1998 version required the fire safety analysis for some facilities, it was
not required to be in writing. Third, the 2001 version requires all propane
facilities that meet the 4,000- gallon criterion to prepare fire safety
analyses. In contrast, the 1998 version required only new (and not existing)
facilities meeting that criterion to prepare fire safety analyses. Fourth,
the 2001 version contains general guidance in an appendix recommending that
propane facilities make their fire safety analyses available to local
emergency response personnel to help them plan for and respond to propane
accidents. The 1998 version did not contain this guidance. To encourage
revisions to the code, EPA participated in NFPA?s consensus- based process.

The nine key stakeholder representatives we contacted who indicated they
were sufficiently familiar with the 2001 version of the code to comment on
it said that the new code would make available more information to local
emergency response personnel. 6 These stakeholders included the
International Fire Marshals Association, the International Association of
Fire Chiefs, the International Association of Fire Fighters, the National
Volunteer Fire Council, the Working Group on Community- Right- to- Know, 7

6 We contacted 18 key stakeholders, of which 9 provided comments.
Representatives who did not comment said either that their organizations had
not prepared an opinion on the code changes or that they were not
sufficiently knowledgeable about the changes to comment.

7 The Working Group on Community Right- to- Know is a public interest group
dedicated to improving the public?s right to know about environmental and
public health concerns. Results in Brief

Page 4 GAO- 01- 709 Changes to the NFPA Code for Propane

an Iowa local emergency planning committee, 8 NFPA, NPGA, and EPA. All but
one of these stakeholders- NPGA- stated that additional changes to the code
or to the process for revising the code should be considered during the next
revision process. The stakeholders had differing views on what specific
changes should be made. Examples of possible changes included standardizing
the fire safety analysis; requiring that fire safety analyses be shared with
local emergency personnel, rather than simply providing guidance on this
subject in the appendix to the code; and accelerating NFPA?s process for
revising the code.

With available information, it is not possible to determine comprehensively
the status of state and local government adoption of the 2001 version of the
code because the code may be adopted in several ways. First, a state may
adopt a version of the code into its law through a legislative or
administrative process. Second, a state may enact legislation that requires
all municipalities within the state to adopt a version of the code. Third,
even if a state takes no action to adopt a version of the code, individual
municipalities within a state may do so. As a result, to determine the exact
extent to which the code has been adopted would require an extensive search
of the laws and regulations of each state and municipality. We did not
perform this search but instead relied on information provided by NPGA.
According to the NPGA information, as of April 16, 2001, 25 states had
adopted the 1998 version of the code, and the remaining 25 states had
adopted earlier versions. NPGA did not have any information on
municipalities? adoption of the code. An NFPA representative estimated that
between 5 and 10 states will have adopted the 2001 code by the end of
calendar year 2001.

We provided a draft of this of this report to EPA and NFPA, both of which
agreed with the report?s findings.

8 Local emergency planning committees were established following the passage
of the Emergency Planning and Community Right- to- Know Act in 1986, which
placed upon state and local governments additional planning and preparedness
requirements for emergencies involving the release or spill of hazardous
materials. These committees are appointed by state emergency response
commissions.

Page 5 GAO- 01- 709 Changes to the NFPA Code for Propane

The 2001 version of the code, effective February 9, 2001, and published
April 4, 2001, strengthens the provisions in prior versions regarding off-
site effects of accidental propane releases in four ways, including
providing additional guidance about making information available to local
emergency response personnel. EPA worked through NFPA?s consensusbased
approach to ensure that the code revisions addressed providing information
to local emergency response personnel about the off- site effects of
accidental propane releases.

The 1998 version of the code explained that preplanning should be
coordinated with local emergency response personnel and that the planning
should consider the safety of the emergency personnel. The 1998 version also
required fire protection for newly built facilities with more than 4,000
gallons of propane on site. The code stated that such protection would be
determined through a fire safety analysis- that is, an evaluation of a
facility?s fire hazards and safety procedures. Finally, an appendix to the
code explained that a fire safety analysis includes various elements, one of
which addresses the off- site effects of accidental releases of propane. 9
Specifically, the appendix indicated that the fire safety analysis addresses
the ?exposure to or from other properties, population density, and
congestion within the site.? There was no requirement for the fire safety
analysis to be in writing.

The 2001 version of the code explains that fire safety planning should
include consideration of the safety of not only emergency personnel, but
also workers and the public. The 2001 code also requires all facilities with
more than 4,000 gallons of propane on site, not just newly built facilities,
to prepare a written fire safety analysis within 3 years of the effective
date of this code. In addition, the appendix to the revised code now
recommends that propane facilities meeting the 4,000- gallon criterion make
their fire safety analyses available to local emergency response personnel.
Specifically, the appendix explains that a fire safety analysis includes ?if
necessary, a designated time period for review of the fire safety analysis
with local emergency response agencies to ensure preplanning and emergency
response plans for the installation are

9 The appendix is not part of the requirements of the code but is included
for informational purposes only. The appendix contains explanatory material,
numbered to correspond with the applicable text of the code. Revised Code

Strengthens Previous Provisions

Code Expands Provisions and Guidance for Fire Safety Analysis

Page 6 GAO- 01- 709 Changes to the NFPA Code for Propane

current.? (See app. I of this report for more information on the contents of
the code.)

According to NFPA officials, in anticipation of the passage of the Chemical
Safety Information, Site Security and Fuels Regulatory Relief Act, which
would result in the exemption of most propane facilities from the
requirement to prepare risk management plans, officials from EPA?s Chemical
Emergency Preparedness and Prevention Office contacted NFPA to learn how to
become involved in the process to revise the NFPA code for liquefied
petroleum gas. Two EPA employees applied to serve on the NFPA Technical
Committee on Liquefied Petroleum Gas, one as a principal member and one as
an alternate. NFPA approved the applications at its July 1999 meeting.

The EPA employee who had applied to serve as a principal member submitted
four proposals for changes by July 1, 1999, the closing date for submitting
proposals for changing the 1998 version of the code. These proposals
included instituting requirements that (1) propane facilities develop some
elements of risk management plans and share the information with local
emergency personnel; (2) propane facilities provide local emergency
personnel with information on any incident in the previous 5 years that
resulted in or could have resulted in a catastrophic release of liquefied
petroleum gas; (3) propane facilities develop and use written operating
procedures for all phases of facility operation, prepare and implement an
equipment maintenance program, self- audit their compliance with the code
every 3 years, investigate any accidents that occur, correct the causes of
any accidents, write a report on each accident, and provide accident reports
to local emergency officials; and (4) facility operators undergo refresher
training at least every 3 years. No other organization submitted proposals
regarding providing information about the off- site effects of accidental
releases of propane to local emergency responders.

According to NFPA, all EPA proposals were discussed during the committee
debate. Some of the proposals submitted by EPA resulted in changes to the
fire safety analysis, as noted earlier, as well as in additional changes
affecting training and facilities operations and maintenance. Other EPA
proposals were rejected, including the ones calling for developing elements
of risk management plans, 5- year accident histories, accident
investigations, and 3- year compliance audits. (See app. I of this report
for more detailed information on the NFPA code revision process.) EPA Led
Efforts to Ensure

the Code Addressed Providing Information to Local Emergency Responders

Page 7 GAO- 01- 709 Changes to the NFPA Code for Propane

The nine key stakeholder representatives we contacted who said they were
knowledgeable about the changes being made to the code told us that the 2001
code would make more information available to local emergency personnel in
order to prepare for and respond to emergencies. All but one- NPGA- told us
that more changes should be considered during the next code revision
process. Representatives of NPGA said that the code should meet the needs of
the local emergency personnel and that no further changes to the code would
be needed. Opinions of the other eight stakeholders varied as to what
additional changes were needed. Although we contacted 18 different
organizations and government agencies, representatives of only 9 commented
on the 2001 version of the code. 10

Three organizations? representatives suggested additional changes intended
to standardize the fire safety analysis.

 The representative from the National Volunteer Fire Council stated that
the changes made to the code might not go far enough to ensure that the
proper information is provided to emergency personnel. However, he also said
that the emergency personnel might not use the information they receive to
plan for an accidental leak or fire. This representative would make further
changes to the code to require facilities to design the fire safety analysis
as a standardized emergency action plan. He went on to say that facilities
should update this emergency action plan every 3 years, or whenever
significant changes occur at the facility.

 The representative from the Working Group on Community Right- to- Know
said that the changes are a good start, but that they do not meet the needs
of local emergency personnel for information about the off- site effects of
accidental releases of propane. This representative would like to see
further changes to the code to include requirements that (1) communities
consider the safety of propane facilities planned for construction compared
with facilities that handle alternative fuels; (2) communities have a role
in planning for the safe placement of facilities; (3) propane

10 Those who did not comment said either that their organizations had not
prepared an opinion on the code changes or that they were not knowledgeable
about the changes. Organizations that did not comment follow: the American
Chemistry Council; the National Association of SARA Title III Program
Officials; the International Association of Emergency Managers; local
emergency planning committees in Louisiana, North Dakota, South Dakota, and
Texas; the U. S. Chemical Safety and Hazard Investigation Board; and the U.
S. Department of Transportation. Stakeholders Said the

New Code Makes Available More Information to Emergency Personnel, but Many
Saw Need for More Changes

Page 8 GAO- 01- 709 Changes to the NFPA Code for Propane

facilities develop site security measures; and (4) propane facilities
develop worst- case scenarios, in a standardized fire safety analysis, for
the effects on the people in the surrounding areas of accidental propane
releases.

 The representative from the International Association of Fire Fighters
wanted the information on what a fire safety analysis should include to
appear in the code itself rather than in an appendix, as it does in the 2001
version of the code. That is, he wanted the contents of the analysis to be
standardized and required in order to better meet the needs of local
emergency personnel.

Officials at two organizations suggested changes to the NFPA code revision
process or to the process for dissemination of information.

 The representative from the International Association of Fire Chiefs said
that, while the code is not perfect, it is one of the finest standards on
fuels or chemicals in this country, and he believes that it meets the needs
of the local emergency personnel. This representative?s only suggestion for
improvement was to accelerate the NFPA process for making changes to the
code, which currently takes 2 years.

 The representative for a local emergency planning committee in Iowa said
that the changes to the code were very good ones. He further said that the
only additional changes he would like to see would be to ensure that all
local emergency personnel be notified when changes to the code have occurred
and that the emergency personnel have the right to review the facilities?
fire safety analyses.

Three other representatives expected to see further changes to the code but
believed it was important to see the effects of the most recent revisions
before deciding what additional changes should be made.

 The International Fire Marshals Association?s representative said that the
2001 version of the code meets the needs of local emergency personnel, but
he hopes that more changes about providing information to emergency
personnel will be made over time.

 An NFPA representative said that the 2001 code is a significant change
from the 1998 code and that technical committee members are anxious to make
more changes to the code about providing information to local emergency
personnel.

Page 9 GAO- 01- 709 Changes to the NFPA Code for Propane

 The Director of the Chemical Emergency Preparedness and Prevention Office
at EPA said the changes made to the code are a significant step toward
providing information to local emergency response personnel concerning the
off- site effects of propane accidents. He also said that EPA intends to
continue to work with the NFPA committee to enhance the code?s requirements
and guidance for providing information to local emergency planners and
responders.

It is not possible, given the information that was readily available, to
determine the status of state and local government adoption of the 2001
version of the code because of the variety of ways in which the code may be
adopted. A state may adopt the code into its law through legislation or an
administrative process. A state may also enact legislation requiring all of
its municipalities to adopt the code. Finally, individual municipalities
within a state may adopt a version of the code while the state itself does
not. As a result, definitively determining the extent to which the code has
been adopted would require an extensive search of the laws and regulations
of each state and municipality. We did not perform this search but instead
relied on information provided by NPGA. According to this information, as of
April 16, 2001, 25 states had adopted the 1998 version, and the remaining 25
states had adopted earlier versions (see table 1). An official of the NFPA
technical committee estimated that between 5 and 10 states will have adopted
the 2001 code by the end of calendar year 2001.

Table 1: NPGA Information on the Number and Percentage of States That Had
Adopted Various Versions of the NFPA Liquefied Petroleum Gas Code as of
April 16, 2001

States that had adopted the code Code version Number Percentage

1998 25 50 1995 14 28 1992 5 10 1989 3 6 1986 1 2 1976 1 2 1972 1 2

Total 50 100

Note: This table presents information for the 50 states; NPGA did not have
information available on territories? adoption of the code.

Source: NPGA data.

Definitively Determining the Status of the Adoption of the Code Would
Require Searching Laws and Regulations of States and Municipalities

Page 10 GAO- 01- 709 Changes to the NFPA Code for Propane

We provided EPA and NFPA with a draft of this report for review and comment.
The Director of EPA?s Chemical Emergency Preparedness and Prevention Office
and NFPA?s Vice President for Codes and Standards Operations orally
commented that the report fairly and accurately presented the information
about the status of the changes to the code. Both organizations also
provided technical comments that clarified information in the report; we
incorporated these comments where appropriate.

We performed our work between October 2000 and June 2001 in accordance with
generally accepted government auditing standards. A detailed description of
our scope and methodology is contained in appendix II.

We are sending copies of this report to the Administrator of the
Environmental Protection Agency; the Vice President for Codes and Standards
Operations, National Fire Protection Association; appropriate congressional
committees; and other interested parties. We will also make copies available
to others upon request.

If you or your staff have any questions about this report, please call me at
(202) 512- 6111. Jeanne Barger and Linda Libician made key contributions to
this report.

David G. Wood Director, Natural Resources and Environment Agency Comments

Appendix I: Contents of the NFPA Liquefied Petroleum Gas Code and the Code
Revision Process

Page 11 GAO- 01- 709 Changes to the NFPA Code for Propane

According to the National Propane Gas Association, 1 the National Fire
Protection Association?s (NFPA) liquefied petroleum gas codes for 1998 and
2001 apply to propane systems such as the following:

 Containers, piping, and associated equipment used to deliver LP- Gas to a
building for use as a fuel gas.

 Highway transportation of LP- Gas.

 The design, construction, installation, and operation of marine terminals
whose primary purpose is the receipt of propane for delivery to
transporters, distributors, or users. The code does not apply to marine
terminals associated with refineries or petrochemical or gas plants. The
code also does not apply to marine terminals whose purpose is to deliver gas
to marine vessels.

 The design, construction, installation, and operation of pipeline
terminals that receive LP- Gas from pipelines under the jurisdiction of the
U. S. Department of Transportation whose primary purpose is the receipt of
LP- Gas for delivery to transporters, distributors, or users. Code coverage
in these situations begins downstream of the last pipeline valve or tank
manifold inlet.

The 1998 and 2001 versions of the code include the same chapters, except
that the 2001 version contains an additional chapter on operations and
maintenance. The 2001 version of the code contains the following chapters:

 Chapter 1- General Provisions- includes definitions, scope, and so on.

 Chapter 2- LP- Gas Equipment and Appliances- includes standards for tanks,
cylinders, valves, piping, and appliances (that is, vaporizers).

 Chapter 3- Installation of LP- Gas Systems- includes guidelines for
installing equipment in bulk plants, in cylinder filling stations, and on
industrial and road vehicles.

1 Propane Education and Research Council and NPGA, Propane Emergencies
(summer 1999). According to an NPGA official, the information in this
publication is also applicable to the 2001 code. Appendix I: Contents of the
NFPA Liquefied

Petroleum Gas Code and the Code Revision Process

NFPA Code Contents

Appendix I: Contents of the NFPA Liquefied Petroleum Gas Code and the Code
Revision Process

Page 12 GAO- 01- 709 Changes to the NFPA Code for Propane

 Chapter 4- LP- Gas Transfer- includes guidelines for filling tanks and
cylinders.

 Chapter 5- Storage of Portable Containers Awaiting Use, Resale, or
Exchange- includes scope, general provisions, storage, and fire protection.

 Chapter 6- Vehicular Transportation of LP- Gas- includes scope,
transportation modes, and parking and garaging vehicles.

 Chapter 7- Buildings or Structures Housing LP- Gas Distribution
Facilities- includes scope and separate and attached structures.

 Chapter 8- Engine Fuel Systems- includes application, general purpose and
industrial vehicles, engine installation, and garaging vehicles.

 Chapter 9- Refrigerated Containers- includes containers, impoundment, and
locating above- ground containers.

 Chapter 10- Marine Shipping and Receiving- includes piers, pipelines, and
actions prior to transfer.

 Chapter 11- Operations and Maintenance- includes scope and operating
requirements.

 Chapter 12- Pipe Tubing and Sizing Tables- includes tables for sizing pipe
and tubing.

 Chapter 13- Referenced Publications- includes documents referenced by the
code that are considered part of the requirements of the code.

In addition, the 1998 and 2001 versions of the code also contain information
and guidance in the following appendixes:

 Appendix A- Explanatory Material

 Appendix B- Properties of LP- Gases

 Appendix C- Design, Construction, and Requalification of Department of
Transportation Cylinders

Appendix I: Contents of the NFPA Liquefied Petroleum Gas Code and the Code
Revision Process

Page 13 GAO- 01- 709 Changes to the NFPA Code for Propane

 Appendix D- Design of American Society of Mechanical Engineers and
American Petroleum Institute Containers

 Appendix E- Pressure Relief Devices

 Appendix F- Liquid Volume Tables, Computations, and Graphs

 Appendix G- Wall Thickness of Copper Tubing

 Appendix H- Procedure for Torch Fire and Hose Stream Testing of Thermal
Insulating Systems for Propane Containers

 Appendix I- Container Spacing

 Appendix J- Referenced Publications

According to NFPA, the process for revising any of its existing codes and
standards, including the liquefied petroleum gas code, involves the
following steps:

 NFPA issues a call for proposals to amend the existing document.

 Technical committee meets to review proposals submitted by the public,
develop its own proposals, and prepare its Report on Proposals.

 Technical committee votes on Report on Proposals by letter ballot. Each
proposal item requires a two- thirds approval by the technical committee
members. Lacking two- thirds approval, the proposal item is deleted from the
report.

 The Report on Proposals is published for public review and comment.

 Technical committee meets to review, consider, and act on public comments
received and prepare the Report on Comments.

 Technical committee votes on the Report on Comments by letter ballot. If
two- thirds of the technical committee members approve, the comments are
included in the Report on Comments. Lacking two- thirds approval, the
comment is deleted from the report. NFPA Code Revision

Process

Appendix I: Contents of the NFPA Liquefied Petroleum Gas Code and the Code
Revision Process

Page 14 GAO- 01- 709 Changes to the NFPA Code for Propane

 The Report on Comments is published for public review.

 NFPA membership meets (annual or fall meeting) and acts on the committee
report (Report on Proposals or Report on Comments). At this meeting, the
association members may, subject to review by the NFPA Standards Council,
adopt a report as published; adopt a report as amended, contingent upon
subsequent approval by the technical committee; return a report to technical
committee for further study; or return a portion of a report to the
technical committee.

 If the report was amended, the technical committee votes on the amendments
to the report approved at the NFPA annual or fall meeting.

 The public may appeal NFPA actions to the Standards Council within 20 days
of the NFPA annual or fall meeting.

 Standards Council decides, on basis of all evidence, whether to issue the
code as amended by the report or to take other action, including upholding
any appeals.

Appendix II: Scope and Methodology Page 15 GAO- 01- 709 Changes to the NFPA
Code for Propane

To describe the revisions to the code regarding information for emergency
personnel about the potential effects of accidental releases of propane to
surrounding areas, as well as the code revision process, we reviewed and
compared the 1998 and 2001 versions of the code. We interviewed
representatives from NFPA, including the Vice President for Codes and
Standards Operations, the Assistant Vice President of Fire Protection
Applications and Chemical Engineering, the Associate General Counsel, and
the Secretary for the Technical Committee on Liquefied Petroleum Gas, and
discussed with them their process for making changes to the code. We also
interviewed officials from the Environmental Protection Agency?s (EPA)
Chemical Emergency Prevention and Preparedness Office about the proposals
made to change the code and the final changes to the code.

To describe the views of key stakeholders about whether the revised code
provides sufficient information to local emergency response personnel, we
interviewed representatives of nine organizations who said they were
knowledgeable about the code changes. These representatives were from the
International Association of Fire Chiefs, the International Association of
Fire Fighters, the International Fire Marshals Association, the National
Volunteer Fire Council, the Working Group on Community Right- to- Know, the
National Propane Gas Association (NPGA), EPA, NFPA, and a local emergency
planning committee in Iowa. During our interviews with these stakeholders,
which took place before the publication and dissemination of the 2001
version of the code, we asked similar questions of each organization about
the information that likely will be made available to local emergency
personnel because of the changes made to the code. We also asked for
referrals to others who might be knowledgeable about the changes to the code
and the availability of information to local emergency personnel. We also
contacted representatives of nine other organizations who said that they
could not comment about the code changes because either their organizations
had not prepared an opinion on the code changes or because the
representatives said they were not knowledgeable enough about the changes to
comment. Those who did not comment were the American Chemistry Council
(previously known as the Chemical Manufacturers Association), the National
Association of SARA Title III Program Officials, the International
Association of Emergency Managers, four local emergency planning committees,
the U. S. Chemical Safety and Hazard Investigation Board, and the Department
of Transportation.

To select the local emergency planning committees, we obtained a list from
NPGA of the 1997 propane sales by state (the latest available data) and
selected the five states with the highest propane sales per capita- Appendix
II: Scope and Methodology

Appendix II: Scope and Methodology Page 16 GAO- 01- 709 Changes to the NFPA
Code for Propane

Iowa, Louisiana, North Dakota, South Dakota, and Texas. We obtained contacts
for each of the local emergency planning committees in these states and
randomly selected one planning committee for each state. When we contacted
the planning committee, we asked to speak with the planning committee member
who was most familiar with propane issues.

To describe the status of adoption of the 2001 version of the code, we
obtained information from NFPA and NPGA on whether states had adopted the
code and, if so, which version. We identified errors in these data, but no
other comparable data were readily available. Therefore, we decided to use
NPGA?s data, which, according to both organizations, are more accurate than
the data provided by NFPA.

(360008)

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