{"operation":"document","citation":"PHMSA Guidance, Statement of Policy for Transporting Hazardous Liquid or Carbon Dioxide in Non-Steel Pipelines","title":"Statement of Policy for Transporting Hazardous Liquid or Carbon Dioxide in Non-Steel Pipelines","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2026-05-18","effective_on":"2026-05-18","summary":"Statement of Policy for Transporting Hazardous Liquid or Carbon Dioxide in Non-Steel Pipelines Document Statement of Policy for Transporting Hazardous Liquid and Carbon Dioxide in Non-Steel Materials.pdf (253.52 KB) Issued Date: Monday, May 18, 2026","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-statement-policy-transporting-hazardous-liquid-or-carbon-4db9ff5d.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-statement-policy-transporting-hazardous-liquid-or-carbon-4db9ff5d.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-statement-policy-transporting-hazardous-liquid-or-carbon-4db9ff5d","source_url":"https://www.phmsa.dot.gov/regulatory-compliance/phmsa-guidance/statement-policy-transporting-hazardous-liquid-or-carbon","body":"Statement of Policy for Transporting Hazardous Liquid or Carbon Dioxide in Non-Steel Pipelines\n\nDocument\n\n Statement of Policy for Transporting Hazardous Liquid and Carbon Dioxide in Non-Steel Materials.pdf (253.52 KB)\n\n          Issued Date: Monday, May 18, 2026\n\n<<<PAGE 1>>>\n\nMay 18, 2026\nSTATEMENT OF POLICY FOR\nTRANSPORTING HAZARDOUS LIQUID OR CARBON DIOXIDE IN NON-STEEL\nPIPELINES\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA) is issuing this\nstatement of policy to provide interested parties with additional guidance for transporting\nhazardous liquid1 or carbon dioxide2 in non-steel pipelines under 49 CFR Part 195. The Federal\nsafety standards in 49 CFR Part 195 generally apply to hazardous liquid and carbon dioxide in\nsteel pipelines. To transport hazardous liquid or carbon dioxide in a non-steel pipeline, an\noperator must comply with the requirements in section 195.8.\nAs originally adopted and amended in subsequent rulemaking proceedings,3 section\n195.8 requires an operator seeking to transport hazardous liquid or carbon dioxide in a non-steel\npipeline to “notif[y] the Administrator in writing at least 90 days before the transportation is to\nbegin. The notice must state whether carbon dioxide or a hazardous liquid is to be transported\nand the chemical name, common name, properties and characteristics of the hazardous liquid to\nbe transported and the material used in construction of the pipeline.”4 Section 195.8 further\nprovides that “[i]f the Administrator determines that the transportation of the hazardous liquid or\ncarbon dioxide in the manner proposed would be unduly hazardous, he will, within 90 days after\nreceipt of the notice, order the person that gave the notice, in writing, not to transport the\nhazardous liquid or carbon dioxide in the proposed manner until further notice.”5\n1 49 CFR § 195.2 (defining “hazardous liquid” for purposes of 49 CFR Part 195 as “petroleum, petroleum products,\nanhydrous ammonia, and ethanol or other non-petroleum fuel, including biofuel, which is flammable, toxic, or\nwould be harmful to the environment if released in significant quantities”).\n2 Id. (defining “carbon dioxide” for purposes of 49 CFR Part 195 as “a fluid consisting of more than 90 percent\ncarbon dioxide molecules compressed to a supercritical state”).\n3 34 Fed. Reg. 15,473, 15,474, 15,477 (1969); 35 Fed. Reg. 5332, 5333 (1970); 35 Fed. Reg. 17,183, 17,184 (1970);\n46 Fed. Reg. 38,357, 36,363 (1981); 56 Fed. Reg. 26,922, 26,925 (1991); 59 Fed. Reg. 17,275, 17,281 (1994).\n4 49 CFR § 195.8.\n5 Id.\n\n<<<PAGE 2>>>\n\n2\nPHMSA has laid out certain important principles in evaluating notices submitted under\nsection 195.8. First and foremost, PHMSA has acknowledged that an operator does not need to\nobtain a special permit to use a non-steel pipeline to transport hazardous liquid or carbon\ndioxide.6 An operator need only provide the notice required by section 195.8;7 if the\nAdministrator does not issue an order objecting to the proposal described in the notice within 90\ndays, the operator is authorized to use the non-steel pipeline without any further action.\nIn addition, PHMSA has applied certain general criteria in evaluating whether\ntransporting hazardous liquid or carbon dioxide in a non-steel pipeline would be unduly\nhazardous. The general criteria include whether pipelines constructed with that material have a\nhistory of operating safely in other environments,\n8 whether the material is authorized for use in\ntransporting gas under 49 CFR Part 192, and, if so, whether the operator will comply with Part\n192 in designing, constructing, testing, operating, and maintaining the proposed pipeline.\n9\nPHMSA has also applied certain specific criteria in evaluating whether transporting\nhazardous liquid or carbon dioxide in a pipeline constructed with a corrosion-resistant, non-steel\nmaterial would be unduly hazardous. The specific criteria include, among other things, whether\nthe material is “manufactured in conformance with a published specification and documented\nquality assurance program.”10\nPHMSA is aware of industry standards that apply to pipelines constructed with non-steel\nmaterials. For example, the American Petroleum Institute and ASTM International have\npublished several such standards for transporting hazardous liquid in non-steel pipelines,\nincluding:\n6 Interpretation Response #PI-83-0100, available at https://www.phmsa.dot.gov/regulations/title49/interp/pi-83-0100\n(“The Part 195 safety standards for hazardous liquid pipelines do not prohibit the use of pipe made of materials other\nthan steel. Thus, a special approval or waiver is not required for the use of such materials. However, as more fully\nstated in §195.8, the use of any material other than steel in a proposed pipeline is conditioned upon the operator of\nthe proposed pipeline giving prior notice to this agency so that a determination can be made about the safety of the\npipeline before transportation begins.”).\n7 Operators interested in submitting a notice through section 195.8 can use the same process for integrity assurance\nnotifications and send by electronic mail to InformationResourcesManager@dot.gov.\n8 Interpretation Response #195.8-1984 Sohio, available at https://www.phmsa.dot.gov/standards-\nrulemaking/pipeline/interpretations/1958-1984-sohio (“This is in response to your letter dated August 10, 1984,\nsubmitting a notification under §195.8 of the proposed use of a 1000’ section and a 420’ section of ‘Pag-O-Flex’\npipe in an offshore pipeline. We understand that this type of flexible pipe has been used successfully offshore in\nsituations similar to those you propose. Further, the proposed test pressure exceeds that required by §195.302(b)(2).\nConsequently, we find that your proposal is not unduly hazardous.”).\n9 Interpretation Response #PI-89-020, available at https://www.phmsa.dot.gov/regulations/title49/interp/pi-89-020.\n10 Interpretation Response #PI-92-0106, available at https://www.phmsa.dot.gov/regulations/title49/interp/pi-92-\n0106.\n\n<<<PAGE 3>>>\n\n3\n• API Specification 15S (Spoolable Reinforced Plastic Line Pipe), which covers the\nrequirements for manufacturing and qualifying spoolable reinforced plastic pipe,\nincluding materials, pipe, and fittings (e.g., steel or nonmetallic reinforced)\n• API Specification 15HR (High-pressure Fiberglass Line Pipe), which specifies\nrequirements for high-pressure fiberglass line pipe, generally covering pipes with\npressure ratings from 500 psi to 5,000 psi\n• API Specification 15LR (Low Pressure Fiberglass Line Pipe), which focuses on low-\npressure applications, covering design and manufacturing for fiberglass piping in oil,\ngas, and water applications, for the construction of pipelines with non-steel materials,\ncovering sizes up to 24-inches and pressures up to 1,000 psig\n• ASTM F2619 (High-Density Polyethylene Line Pipe), which focuses on high density\npolyethylene pipelines for oil and gas production, including transportation of liquids,\nsuch as oil, dry or wet gas, multiphase fluids, and non-potable oilfield water\n• ASTM F2896 (Reinforced Polyethylene Composite Pipe), which focuses on on-site\nmanufactured multilayer reinforced polyethylene composite pipe for “transport of\ncrude oil, natural gas and hazardous liquids in the rehabilitation of existing pipelines\nand for new pipelines”\nPHMSA is also aware of other industry standards that focus more on the transportation of\ncarbon dioxide in non-steel pipelines, including:\n• DNV-RP-F104 (Design and Operation of Carbon Dioxide Pipelines), which addresses\nnon-metallic materials for carbon dioxide pipelines\n• API Recommended Practice 1192 (Transportation of Carbon Dioxide by Pipeline),\nwhich focuses on transportation of carbon dioxide by steel pipeline but contains some\ninformation on non-metallics and non-metallic components\nOther organizations have published comparable standards for the transportation of\nhazardous liquid or carbon dioxide in non-steel pipelines as well.11\nWhile not currently incorporated by reference into Part 195, PHMSA understands that\npipelines designed, constructed, tested, operated, and maintained in accordance with the above-\nreferenced industry standards can be safely used in hazardous liquid or carbon dioxide service.\nPHMSA also understands that transporting hazardous liquid or carbon dioxide in a non-steel\npipeline may be more appropriate than using a steel pipeline in certain circumstances.\nTo facilitate the appropriate use of non-steel pipelines, PHMSA is issuing a new policy\nfor evaluating notices submitted under section 195.8. Specifically, the Administrator will\ngenerally refrain from exercising his discretion to issue an order prohibiting the transportation of\n11 See e.g., CSA Z662 (Oil and Gas Pipeline Systems).\n\n<<<PAGE 4>>>\n\n4\nhazardous liquid or carbon dioxide in a non-steel pipeline, so long as the 90-day prior written\nnotice submitted by the operator provides the information necessary to demonstrate that the\npipeline will be designed, constructed, tested, operated, and maintained in accordance with\nrecognized and generally accepted industry codes and standards.\nPHMSA would generally find the following information, to the extent not otherwise\nrequired by regulation, to be useful when making its necessary determination on a 90-day prior\nnotice submitted under section 195.8:\n• A list of the industry codes and standards that the operator intends to follow in\ndesigning, constructing, testing, operating, and maintaining the pipeline\n• A description of the hazardous liquid or carbon dioxide that the operator intends to\ntransport, including the chemical name, common name, properties, and characteristics\nof the product\n• Information showing that the non-steel material is compatible with the product being\ntransported, including chemical compatibility, permeation, delamination, effects on\nelastomers, decompression behavior, fracture behavior, etc.\n• Information regarding the long-term performance of the non-steel material in the\nproposed service, including any testing results validating performance at applicable\npressures and temperatures for the product being transported\n• The written procedures that the operator intends to follow to ensure compliance with\nthe listed industry codes and standards, as well as any manufacturer specifications\nand instructions and other generally accepted and recognized engineering practices\n• The written integrity management plan that the operator intends to implement to\nprotect high consequence areas\nThis statement of policy does not relieve the owner or operator of a non-steel pipeline of\nits obligation to comply with the requirements in the Pipeline Safety Act (PSA), 49 U.S.C. §\n60101 et seq., or Pipeline Safety Regulations (PSR), 49 CFR Parts 190 to 199, where applicable.\nThat includes the obligation to develop and implement a plan for inspecting and maintaining the\nnon-steel pipeline and, if necessary, to submit that plan to PHMSA for approval under 49 U.S.C.\n§ 60108. It also includes the obligation to ensure that any steel pipeline facilities in a non-steel\npipeline system comply with the applicable requirements in the PSA or PSR. Nor does this\nstatement of policy prohibit PHMSA from exercising any of the powers or authorities granted in\nthe PSA or PSR, including by conducting inspections and investigations and initiating\nenforcement actions or other administrative or judicial proceedings against owners or operators\nof non-steel pipelines used to transport hazardous liquid or carbon dioxide, either before or after\nsubmitting the notice required by section 195.8.\nFinally, this statement of policy does not have the force and effect of law and is not\nmeant to bind the public in any way, and is intended only to provide clarity to the public\n\n<<<PAGE 5>>>\n\nregarding existing requirements under the law or agency policies, and compliance may be\nachieved in more than one way.\n_________________________\nLinda Daugherty\nActing Associate Administrator, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n5","truncated":false,"body_characters":12078}