# BP Oil Pipeline Company — Pipeline Safety Interpretation

**Citation:** PI-94-032  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 1994-10-17

PI-94-032 response to BP Oil Pipeline Company concerning 195.402.

## Document text

<<<PAGE 1>>>

October 17, 1994
Mr. L. S. Abraham
Health & Compliance Officer
BP Oil Pipeline Company
812 E. National Road
Vandalia, OH 45377-3016
Dear Mr. Abraham:
I have reconsidered my initial response to your letter of December 16, 1993, concerning
procedures required by 49 CFR 195.402(c)(4). Under this regulation, operators must have
procedures for “ determining which pipeline facilities are located in areas that would require an
immediate response by the operator to prevent hazards to the public if the facilities failed or
malfunctioned.”
Initially I supported the view that BP’ s policy of responding immediately to every failure or
malfunction, regardless of location, would not meet § 195.402(c)(4). According to your letter,
some of our inspectors had asked BP to identify environmentally sensitive, highly populated,
industrial, and agricultural areas along its pipelines; to state how it would respond to each area;
and to establish response priorities.
Based on the regulatory history cited in my earlier letter, it’ s apparent that operators only have to
identify their high risk facilities to comply with § 195.402(c)(4). So, by identifying all its facilities,
as BP apparently has done, an operator would not only meet but exceed the requirements of
§ 195.402(c)(4).
In addition, § 195.402(c)(4) does not require operators to have plans and priorities to respond to
failures or malfunctions at facilities under that section. However, response plans are a [sic]
essential part of the emergency procedures required by § 195.402(e) and of the abnormal
operation procedures required by § 195.402(d). Also, under § 195.402(c)(6), operators must
take steps to minimize the potential for hazards to occur at the facilities identified under
§ 195.402(c)(4).
I hope you were not too inconvenienced by my initial response. But please don’ t hesitate to write
if you need any additional information regarding our regulations.
Sincerely,
Cesar De Leon
Director for Pipeline Safety
Regulatory Programs
dal/195.402
94-10-17

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94032.pdf>
- Source ID: `phmsa`
- SHA-256: `fe66fee5ec018c6a93c846f9eca7f06ebd4cc3a38d13e5c7af6fe6e224c074cc`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-22T11:51:45.275Z
- Document slug: `phmsa-interpretation-pi-94-032`

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```