{"operation":"document","citation":"PI-12-0008","title":"Associated Safety Consultants, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-12-20","effective_on":null,"summary":"PI-12-0008 response to Associated Safety Consultants, Inc. concerning 192.317.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-12-0008.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-12-0008.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-12-0008","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/Pipeline/2012/AssociatedSafetyConsultants-08172012-Pt192_317.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation 1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nPipeline and Hazardous Materials\nSafety Administration\nDEC 2 0 2012\nMr. Michael J. Frenzel\nAssociated Safety Consultants, Inc.\n8315 Kelwood A venue\nSuite B\nBaton Rouge, LA 70806\nDear Mr. Frenzel:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nAugust 9, 2012, the Associated Safety Consultants (ASC), Inc., requested an interpretation ofthe\napplicability of the Federal pipeline safety regulations at 49 CFR 192.317(b) to an aboveground\ngas transmission line or main. Specifically, ASC asks PHMSA's interpretation of how a 'safe\ndistance' is defined or determined, and what would constitute an effective barricade?\nSection 192. 317(b) reads as follows:\n(b) Each aboveground transmission line or main, not located offshore or in inland\nnavigable water areas, must be protected from accidental damage by vehicular\ntraffic or other similar causes, either by being placed at a safe distance from the\ntraffic or by installing barricades.\nPHMSA has not adopted general criteria to judge the safety of distances and effective barricades\nseparating aboveground gas pipeline facilities from vehicular traffic. Therefore, a safe distance\nand effective barricade would be whatever a reasonable and prudent pipeline operator would\nconclude is safe under the site specific circumstances, considering relevant factors such as the\nspeed limit, the direction of traffic, the terrain, and any natural barriers.\nI hope that this information is helpful to you. If I can be of further assistance, please contact me\nat 202-366-4046.\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n/>[-/1--cc~ Y\nASSOCIATED SAFETY CONSULTANTS, INC.\nProviding Safety Program Management Services to Business and Industry\n8315 Kelwood Avenue, Suite B, Baton Rouge, Louisiana 70806\nPhone (225) 926-0560, Fax (225) 926-1509\nAugust 9, 2012\nOffice of Pipeline Safety (PHP-30)\nPHMSA\nUS Department of Transportation 1200 New Jersey Avenue, SE\nWashington DC 20590-0001\n'AUG 1'1 ln,1\nRE: Interpretation of 49CFR 192.317(b)\nDear Sir:\n49CFR 192.317(b) reads in part that 'Each above ground transmission line or\nmain ... must be protected from accidental damage by vehicular traffic or other\nsimilar causes, either by being placed at a safe distance from the traffic or by\ninstalling barricades.'\nMy questions are:\nAssuming a safe distance means from a highway or roadway, how is a\n'safe distance' defined or determined, and by whom?\nWhat would constitute an effective barricade?\nIf my questions are not clear, please call. Otherwise, I eagerly await your\nresponse.\nSincerely,\nASSOCIATED SAFETY CONSULTANTS, INC.\nr---\nMICHAEL J. FR 'CSP","truncated":false,"body_characters":3237}