# Ira Jane Hurst & Associates — Pipeline Safety Interpretation

**Citation:** PI-92-017  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 1992-04-15

PI-92-017 response to Ira Jane Hurst & Associates concerning 199.7.

## Document text

<<<PAGE 1>>>

April 15, 1992
Ms. Ira Jane Hurst
Ira Jane Hurst & Associates
P.O. Box 3162
Lafayette, LA 70502
Dear Ms. Hurst:
This is in response to your letter of February 6, 1992, to Mr.
Lamar Allen, Department of Transportation, requesting guidance
concerning the anti-drug plan requirements for pipeline operators
subject to Research and Special Programs Administration (RSPA)
Part 199.
Your correspondence indicated that your firm had noted some
discrepancy among several states with regard to their
interpretation and enforcement of the Part 199 drug testing
regulations. This discrepancy was also noted among inspectors
within a particular state. You indicated that your firm had
developed an anti-drug plan format which was used for a client
who has more than one company located in different regions. Both
companies had the same identical plan and in one case an
inspector found the plan sufficient and in the other region it
was found to be inadequate and did not meet the RSPA
requirements.
You requested this office review your anti-drug plan with regard
to comments noted on a pipeline operator's plan and comments from
a state inspector. This office does not review nor do we approve
anti-drug plans for pipeline operators or consortiums. Each
state that has adopted Part 199 has established inspection
criteria and enforcement policy with regard to drug testing and
plans. Because the inspection criteria and inspection policy may
vary somewhat from state to state, some states may perform more
rigorous inspections. We provide latitude for states to develop
their own inspection program and therefore, there may be some
variations between states in the stringency of enforcement.
A cursory review of the anti-drug plan you submitted for the
particular pipeline operator in question appears to have some
deficiencies that are not consistent with the requirements of
Part 199. If the anti-drug plan was formulated using the Federal
Aviation Administration (FAA) criteria as indicated in your
correspondence, this may account for some of the deficiencies as
their drug criteria is somewhat different from RSPA's
requirements.
dal\199\7\92-04-15
1

<<<PAGE 2>>>

2
Thank you for your inquiry. Please let me know if you need any
more information about our drug testing requirements.
Sincerely,
Richard L. Rippert
Drug Compliance Coordinator
Office of Pipeline Safety
Enforcement
dal\199\7\92-04-15
2

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1992/PI92017.pdf>
- Source ID: `phmsa`
- SHA-256: `d3ba212c3ccce2cf46da654da0ca3ba13602d3898696e60c5d7a704c317090c2`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T07:19:34.280Z
- Document slug: `phmsa-interpretation-pi-92-017`

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