Not for every system. The full 49 CFR 192.616 program requires English. Other languages are required when a significant number and concentration of local non-English speakers commonly understand them. The rule does not name Spanish for all systems. Check paragraph (j) for an exception.
By Bill Stomp · Last updated:
Primary sources: 49 CFR 192.616 · 49 CFR 192.1.
Which language rule applies?
First check the system’s scope under 49 CFR 192.1. Then read 49 CFR 192.616 paragraphs (g) and (j). Paragraph (g) bases the language duty on people in the operator’s area.
Paragraph (j) has an exception to paragraphs (a) through (g). It covers master-meter and petroleum-gas operators unless gas transport is their primary activity. That means their main work. They use a written procedure. It calls for two messages a year. Ask your regulator which path fits.
How can we make the message useful?
We suggest checking which languages the audience understands. Have a qualified reviewer check the safety meaning of each version. Keep the final copy with the list and sending record.
Other rules may still apply under paragraph (j). Check state rules and your system’s procedure too. Review retail warnings as a separate job. First find out which rule fits. Then choose the language for the piece.
Questions owners ask
Does paragraph (g) specifically say Spanish?
No. English is required. Other languages are required when a significant number and concentration of local non-English speakers commonly understand them. Check your audience.
Does paragraph (g) automatically apply to paragraph (j)?
No. Paragraph (j) excepts qualifying operators from the program in paragraphs (a) through (g). Check the exception and any other rules with your regulator.
Should a retail mailing use the same language decision?
Review that separately. Ask which language the people using propane understand. Have a qualified reviewer check the meaning, and save the exact version sent.
General information, not legal advice. Check your system’s rules with your pipeline regulator and your own lawyer.
List the languages your customers use. Then ask us to review the proposed notice versions.