Jurisdictional Systems
If you are a propane retailer, chances are you have heard the phrase ‘jurisdictional account” at least once or check these guys out to learn about it. If you are lucky, you know the term, and either have your jurisdictional house in order—or have no jurisdictional accounts at all.
Should neither of the conditions above apply to you, this I something you ought to get up to speed on. The following is a very brief overview summary of a presentation by Ed Anderson of LP Gas Training & Consulting at the New York Propane Gas Association Spring Conference in Albany, N.Y., in late March.
The federal government is primarily responsible for developing, issuing, and enforcing pipeline safety regulations. There are, however, many states that have partnered with the federal government to provide enforcement via state agencies for intrastate systems. The state may also adopt additional or more stringent regulations.
Jurisdictional Systems are propane systems that serves multiple dwellings, buildings, or businesses and can include single dwellings, buildings or businesses when the system is not entirely on the customer’s premises and a portion of the system is in a public place. According to the Office of Pipeline Safety, enforcement policy jurisdiction ends at the outlet swivel of the (customer) meter or the connection to a customer’s piping, whichever is further downstream. So, what is a jurisdictional system?
CONDITION 1: You have ten or more customers supplied from a single tank or multiple tanks manifolded together. Note that the propane tank or tanks’ location in this scenario does not matter. Consider for instance 9 apartments and 1 utility room outlet for a gas dryer, or a single apartment building with 10 or more apartments, an apartment complex of two or more buildings, a condominium complex, a mobile home park, a campground, etc. As long as there are 10 or more customers serviced by the system, it is jurisdictional.
CONDITION 2: You have multiple customers where a portion of the system is in a public place. You have more than one customer supplied from a single tank or multiple tanks manifolded together, where a portion of the system is located in a public place. (A customer is defined as an end user who has control of the gas usage.) This system could consist of a strip mall with several businesses; a manufacturing business that has a credit union within it (the credit union is open to the public); a condominium complex with less than 10 customers, if it has a laundromat open to the public (with gas dryers) and is tied into the same gas system; or a real estate office and a dentist in the same building, if both have a propane appliance controlled by each individual business.
CONDITION 3: A jurisdictional system can also be present when a single customer’s system is not entirely on the customer’s premises, and a portion of the system is in a public place. Consider a system where the tank(s) serving the customer is/are not located on the customer’s property, and part of the system is in a public place (e.g., the supply line crosses under a road or public right-of-way). In this example, the customer does not have to be a commercial establishment, retail business, or multiple units.
NON-JURISDICTIONAL: A propane system is considered non-jurisdictional if it has fewer than 10 customers and no portion of the system is located in a public place. Also, a system is considered non-jurisdictional if the system is located entirely on a single customer’s premises (no matter if a portion of the system is located in a public place). To comply with jurisdictional requirements, you will have to address requirements of a propane operator, written plan requirements, qualifying employees, reporting incidents and more.
Need help with your compliance with jurisdictional systems? Contact your state or regional propane association, or email me at shane.sweet@nypropane.com.