PLAN: Language requirements/how to determine
The requirement to consider the languages commonly understood by an operator’s stakeholder audiences—especially affected public and excavators—is not new. However, implementation of the requirement has also long been a source of confusion among operators. This, at least in part, drove the additional baseline requirement for a process to identify languages other than English. Further, operators are instructed to determine what “significant number and concentration” means for their pipeline system, operating area, and public awareness program.
In API RP 1162, Third Edition, the baseline requirement regarding languages is two-fold:
- An operator shall conduct their baseline programs in English and in other languages commonly understood by a significant number and concentration of the non-English speaking population in the operator’s area.
- Operators shall identify a process to determine any languages other than English that are commonly understood by a significant number and concentration of the non-English speaking population in the operator’s area and are part of the affected public audience.
The program should include the operator’s determination of “significant number and concentration” and provide data source(s) used in identifying appropriate languages.
As noted in the Third Edition, some data sources may include census data, the American Community Survey, consumer demographic data, and local knowledge of the operating area.
Some operators use zip codes to identify their non-English language populations, others use county-level data or knowledge within other departments in their company.