# John T. Stanclift — Pipeline Safety Interpretation

**Citation:** PI-73-015  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 1973-06-22

PI-73-015 concerning 192.723.

## Document text

<<<PAGE 1>>>

June 22, 1973
Mr. John T. Stanclift
114 Woodlawn Street
Geneva, Ohio 44041
Dear Mr. Stanclift:
Your letter of May 23, 1973, questions two areas of the Federal gas pipeline safety regulations
about which you say you are concerned as a result of actions taken by the East Ohio Gas
Company.
You ask first for clarification regarding §192.453 and the company's action in transferring the
monitoring and maintenance of cathodically protected pipelines from the corrosion department to
the construction and maintenance department. Section 192.453, in pertinent part, requires that
the operator's procedures for the operation and maintenance of cathodic protection systems be
carried out by, or under the direction of, a person qualified by experience and training in pipeline
corrosion control methods. The company letter of April 18, 1973, a copy of which you
forwarded, explained certain steps that are being taken, but did not indicate a violation of
§192.453, and your letter does not explain in what respect safety may be adversely affected by the
company action. This office is not in a position to comment on a company's internal organization,
and our concern is only that the procedures be carried out by, or under the direction of, properly
qualified personnel as required by the regulation regardless of where the personnel are placed in
the company's organization.
You also ask whether gas detection surveys must be made on the inside of buildings under the
§192.723(b)(1) requirement that surveys be conducted yearly on distribution systems in business
districts. The answer does not depend on the definition of business district, but rather on whether
the lines in question are classed as service lines and thereby subject to the regulations. A service
line is defined as 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 the
usual case, the customer meter serving a building is at or near the building wall, and all piping
downstream of the meter inside the building is customer's piping. Such piping is not included
within the definition of service line and, therefore, is not subject to the gas detector survey
requirements of §192.723.
dal\192\723\73-06-22
1

<<<PAGE 2>>>

If you have further questions in these areas, please contact us.
Sincerely,
/signed/
Joseph C.Caldwell
Director
Office of Pipeline Safety
dal\192\723\73-06-22
2

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/PI73015.pdf>
- Source ID: `phmsa`
- SHA-256: `e04a011665e0e17014d404d9292ead43c0baa5e0c99aef94d6161b3ee699771d`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-22T10:08:29.009Z
- Document slug: `phmsa-interpretation-pi-73-015`

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