§190.11 Availability of informal guidance and interpretive assistance.

Advisory Bulletin  dated July 29, 1993

Advisory Bulletin #:  ADB-93-04

Issue Date:    11/16/93
CFR Reference(s):
Keyword(s):    Regulation

Persons Seeking Interpretations of Pipeline Safety Regulations Include Certain Information

US Department of Transportation, 400 Seventh Street, SW.
Research and Special Programs Administration Washington, DC  20590

Advisory Bulletin:    ADB-93-04    Date:  11/16/93

To:    Owners and Operators of Gas and Hazardous Liquid Pipeline Facilities

Subject:    Persons Seeking Interpretations of Pipeline Safety Regulations Include Certain Information

Purpose: This advisory bulletin requests that persons seeking interpretations of pipeline safety regulations include certain information.

RSPA requests that owners and operators of gas and hazardous liquid pipelines and other persons requesting interpretation of regulations from the Office of Pipeline Safety (OPS) Washington Office include the following information in the request:

  • Specify the regulations to be interpreted and provide adequate information on the circumstances regarding the interpretation requested.
  • Specify whether there is a current or past OPS or State interpretation or compliance action on the regulation(s) relating to the interpretation requested; and, if so, provide to the State enforcement office or OPS Regional Office a copy of the letter sent to OPS requesting and interpretation.


RSPA often receives requests for interpretations of regulations from operators that have been cited for violation of the regulation(s) involved, and against whom enforcement actions have been initiated.  Including information on existing compliance actions with operators requests for interpretations will help prevent inconsistencies between interpretations given and decisions on compliance or enforcement cases that are in process.

Issued in Washington, DC, on November 16, 1993.
George W. Tenley, Jr., Associate Administrator for Pipeline Safety


The Daily Interpretation

This category will have Interpretations,  Advisory Bulletins and Waivers from the pipeline regulations found in 49 CFR Parts 190-199.  Interpretations are made available under 190.11(b) and  over 1000 are currently available.  Advisory Bulletins and Waivers are also used to provide guidance for compliance with the regulations.  If you have a suggestion or request for an interpretation on a specific topic, please submit a comment.

Use the drop-down menu at the left or the category listing in each post to display all posts in The Daily Interpretation.

WinDOT, The Pipeline Safety Encyclopedia, the #1  reference application for the federal Pipeline Safety regulations, has all this information and more. The regulations, interpretations and amendments are all linked to make finding the pertinent documents simple and uncomplicated. For more information please use the “Contact Us” link to the left.

PHMSA asks for additional comments on forms

Today PHMSA published an additional request in the Federal Register for comments on the revisions to incident and accident reporting forms.  In September last year PHMSA published their initial requests with sample forms showing revisions in the data collection. Numerous comments were received and today’s notice includes the comments and PHMSA response.

PHMSA currently has a an open docket on changes to reporting methods which includes a change in the definition of “incident” in Part 191.  This change in the reporting method will include the new incident/accident forms referenced in today’s notice.

White House announces new PHMSA admin


Office of the Press Secretary

For Immediate Release                                                       August 14, 2009

President Obama announced his intent to nominate the following individual today:

Cynthia L. Quarterman, Administrator, Pipeline and Hazardous Materials Safety Administration, Department of Transportation

Cynthia L. Quarterman is a partner in the Washington, DC office of the law firm Steptoe & Johnson LLP, where she has a regulatory and litigation practice in the areas of transportation and natural resources. She has more than 20 years of experience in the transportation of hazardous materials by pipeline. Quarterman served as a past Director of the Minerals Management Service at the Department of the Interior, which oversees the leasing, exploration and resource development on the Nation’s outer continental shelf, including the transportation of hazardous materials by pipeline. Quarterman earned a Juris Doctorate degree from Columbia University’s School of Law and a Bachelors of Science in Industrial Engineering degree from Northwestern University.

Odorization conference announced

Clarion Technical Conferences has announced it will hold the Natural Gas Odorization International Conference & Exhibition in Houston, TX, on May 25-26, 2010.  This is the first such meeting in several years and will cover all aspects of odorization.

A “Call for Papers” was issued inviting odorization experts from around the world to submit abstracts for review.  More information can be found at http://www.clarion.org/naturalGas/naturalGas10/main.php.

Odorization requirements for gas pipelines can be found at 49 CFR 192.625.  Distribution lines are required to be continuously odorized, transmission lines have varying requirements and in many cases are not odorized at all.  Odorization is a complex operation that needs close attention to be effective.

PHMSA last amended the odorization regulations in 2003 to require odor testing be done with an instrument capable of measuring the gas-in-air concentration at which gas is readily detectable.  “Readily detectable” can vary by person, so perhaps a definition of the concept is in order.

Readily detectable odoran odor that can be discovered, determined or whose existence can be identified in a ready manner, without hesitating or much difficulty.

How do operators ensure their personnel understand this concept, so as to be able to report correctly when testing odor intensities?  Perhaps a better way of understanding this idea of readily detectable is to put it in a different perspective.  “The odor of gas should be one that a spouse, family, or member of the general public would quickly recognize, prompting them to take appropriate action.”

You can read additional information on odorization by clicking on the “Complying with odorization regulations” link to the right.

The Natural Gas Conference will explore this and all other facets of odorization from selecting an odorant, injection rates, testing and clean up.

Pipeline Security, serious business

The TSA posted a notice in today’s Federal Register requesting comments on a new data collection requirement.  TSA will soon be publishing “Pipeline Security Guidelines” to replace the current Pipeline Security Information Circular issued on September 5, 2002.  Included in the Guidelines will be a request for security information, including an operator’s primary security contact and notification if various security events occur.  Submission is voluntary.

Recommendations from the 9/11 Commission Act of 2007 (Public Law 110-53) include provisions for the Department of Homeland Security and DOT to review review operator security plans.  The departments will work to prioritize risks and response actions and if necessary develop regulations for pipeline security.

Pipeline security is serious business.  We’ll have more information as it is made available.

Waiting for DIMP

Distribution companies are anxiously awaiting the final rule on Distribution Integrity Management as we progress through the summer.  The expectation is the rule may be released in September.  It is believed to be under review (possibly completed) at the Secretary’s office and then on its way to OMB before publication.

What changes can we expect?  Without seeing the rule itself it is impossible to know, but several presentations on DIMP have presented a glimmer of what we may see in the final rule.  The following is unofficial, obtained from TPSSC records and industry presentations.

  • Records – a reduction in the record keeping and documentation requirements.
  • Performance Through People (PTP)- removed from the rule.
  • Plastic pipe failure reporting, removed and mechanical/compression coupling failure reporting added.
  • Definition of hazardous leak added and damage further defined as excavation damage.
  • Clarification of who would approve alternative intervals for inspections (federal/state agency).
  • Master meters and LPG may have additional risk ranking requirement.
  • EFV locations further defined.

Threat identification and risk ranking are key activities in developing an operator’s DIMP.  Knowledge of the system is crucial to effectively completing these tasks.  A good comprehensive continuing surveillance program will provide much of this information, along with leak repair, corrosion control and damage prevention data.  It is not too early to start identifying these and other resources that will will needed to develop the required plan.