# Public Works Department — Pipeline Safety Interpretation

**Citation:** PI-73-0110  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 1973-06-06

PI-73-0110 response to Public Works Department concerning 192.3.

## Document text

<<<PAGE 1>>>

PI-73-0110
06-06-73
Ronald N. Hutton, P.E.
Chief, Buildings Division
Public Works Department
Tacoma, Washington, 98402
Dear Mr. Hutton:
Your letter of May 10, 1973, describes a certain gas pipeline installation and asks whether the
line in question is a service line.
In the given situation, there is a tee downstream of the meter with line branch going into a house.
A second branch goes back into the ground and on to another building which is described as an
accessory building. It is the classification of the line to the accessory building that is in question.
The piping into the house is referred to as customer's piping. However, it is not clear whether the
customer or the gas company owns the piping to the accessory building. Neither does the
description explain whether the gas to the accessory building is being used for the customer's
own purposes or whether he is reselling the gas to a tenant living in that building.
The term "service line" was recently redefined in Amendment 192-13. As here pertinent, service
line means a distribution line that transports gas from a common source of supply to a customer
meter or the connection to a customer's piping, whichever is farther downstream.
In a situation where the customer is using the gas in the accessory building for his own purpose
and owns the piping to that building, the service line ends at the outlet side of the meter. In that
case the customer-owned lines downstream of the meter are not service lines within the
definition and, therefore, not subject to the Part 192 regulations. On the other hand, where the
line to the accessory building is owned by the gas company (operator), then the line would be
classed as a service line down to the point at which it connects to the customer's piping.
If the gas to the second building is being supplied by the "customer" to a tenant, or is metered
separately by the operator, other considerations become involved and we would need a more
complete description of the system to determine the classification of the lines.
I trust this has been of some help to you. If you would like further clarification, we will be glad
to respond.
Sincerely,
/signed/
Joseph C. Caldwell, Director
192.3 SERVICLI 1

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/g73-06-06_Hutton_192%203_Service%20Line-nlmx.pdf>
- Source ID: `phmsa`
- SHA-256: `b342c7666db6753c055f9fe51bf92abd2514e682148ef3f81013ae16cfc63c3b`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-22T16:42:46.660Z
- Document slug: `phmsa-interpretation-pi-73-0110`

### Source metadata

```json
{
  "materialSubtype": "interpretation",
  "interpretationArea": "pipeline_safety",
  "representation": "full_text_from_official_pdf",
  "companies": [
    "Public Works Department"
  ],
  "individuals": [
    "Ronald N. Hutton"
  ],
  "refIds": [
    "PI-73-0110"
  ],
  "catalogDates": [
    "1973-06-06"
  ],
  "catalogParts": [
    192
  ],
  "catalogRowCount": 1,
  "sourceRecordUrls": [
    "https://www.phmsa.dot.gov/node/61831"
  ],
  "linkedAttachmentUrls": [],
  "unavailableResponseUrls": [],
  "duplicateRepresentationUrls": [],
  "citedSections": [
    "192.3"
  ],
  "catalogPageUrls": [
    "https://www.phmsa.dot.gov/regulations/title49/section/1923"
  ],
  "pdfUrls": [
    "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/g73-06-06_Hutton_192%203_Service%20Line-nlmx.pdf"
  ],
  "representations": [
    {
      "viewUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/g73-06-06_Hutton_192%203_Service%20Line-nlmx.pdf",
      "detailUrl": null,
      "detailHtmlPath": null,
      "pdfUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/g73-06-06_Hutton_192%203_Service%20Line-nlmx.pdf",
      "pdfArtifactPath": "data/sources/phmsa-interpretations/pi-73-0110.pdf",
      "pdfArtifactSha256": "2cc60e321e6602aa2f30ff3b86f2cbba02c0bdf2b679fda64f0159d02e97bb29",
      "extractedTextPath": "data/sources/phmsa-interpretations/pi-73-0110.v2.txt",
      "extractedTextSha256": "691448d66375a034ca433d4fc32364f29e1c68dea81975d32ef4ea30f9247695",
      "pageCount": 1,
      "extractionVersion": 2
    }
  ],
  "caveat": "Interpretations apply regulations to the facts presented and do not create independently enforceable requirements.",
  "jurisdiction": "US"
}
```
