# ADB 72-2 — Pipeline Safety Interpretation

**Citation:** PI-72-047  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 1972-02-01

PI-72-047 response to ADB 72-2 concerning 192.195, 195.1, 195.210.

## Document text

<<<PAGE 1>>>

From OPS Adv. Bul. no. 72-2
Interpretations
Relates to 49 CFR Part 191
Question: Is a gas leak that occurred inside a house reportable
under the provisions of 49 CFR Part 191?
OPS Interpretation: "...any leak...(an unintended escape of gas)
that is caused by a defect or act on a pipeline facility over which
the Department has jurisdiction is reportable under Part 191. This
assumes that the leak meets the other criteria for reporting that
are stated in those regulations. If, however, the defect or act,
and the escape of the gas resulting therefrom occurs outside our
jurisdiction, then it is not reportable under Part 191.
..."To assist in carrying out the regulatory responsibility,
Section 12 of the Act requires operators to '...maintain such
records, make such reports, and provide such information as the
Secretary may reasonably require...' Based upon this
authority...reporting is required with respect to those pipeline
facilities and activities where there is jurisdiction to act.
Requiring a report if incident that proximately results in the
escape of gas and danger to the public, regardless of the physical
location of that escape and danger, is a reasonable exercise of the
authority."
..."In short, if the act that causes the escape or danger occurs
where there is authority to regulate a report is required
regardless of the physical location of the escape."
Relates to 49 CFR ?192.195
Question: Is there any intent in ?192.195 to limit the use of some
types of overpressure protective devices that were previously
permitted under certain conditions under the interim standards such
as relief, monitoring, rupture discs, shut-off and series
regulation?
OPS Interpretation..."Except as specifically provided for in
?192.195, there is no intent to limit the type of overpressure
protection device that an operator may use. The operator is free
to choose the device...that will best suit his situation so long as
it complies with applicable requirements of Part 192."
Question: What is the effect of the Occupational Safety and Health
Act of 1970 upon the safety rules and regulation for the
transportation of natural gas and liquids via pipeline?
DB
C:\WP51\INTERPRT\195\210\00-00-00
1

<<<PAGE 2>>>

OPS Interpretation:..."The regulations promulgated under the
authority of the Occupational Safety and Health Act of 1970 and
under the Natural Gas Pipeline Safety Act of 1968 are compatible as
they apply to the different aspects of safety for which the Acts
were enacted. The pipeline regulations apply to the safe
transportation of natural and other gas and liquids by pipeline.
The Occupational Safety and Health regulations apply to the safety
of the worker. Where safety in transportation demands regulations
affecting work conditions of workers then the Department of
Transportation assume(s) jurisdiction."
Relates to 49 CFR ?195.210
Question: What would be the reaction of the pipeline safety office
to the encroachment of a surface-holder upon the 50-foot
restriction of ?195.210?
OPS Interpretation:..."The 50 foot restriction on ?195.210 applies
only to installation of the pipeline and does not affect any
subsequent encroachment by a surface holder. Once the pipeline is
in place these regulations have no limitations on how close surface
structures can be placed to the pipeline. The terms of the
operator's right-of-way would be the only limiting factor."
DB
C:\WP51\INTERPRT\195\210\00-00-00
2

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1972/PI72047.pdf>
- Source ID: `phmsa`
- SHA-256: `0423cf48fd8af17d1980ff7c8f42dae60c87765a1703ca85d922fe7067301102`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-22T04:59:43.430Z
- Document slug: `phmsa-interpretation-pi-72-047`

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