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 Act4

 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

 10Those 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.

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