{"operation":"document","citation":"PI-71-066","title":"Associated Corrosion Consultants Ltd. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-07-22","effective_on":null,"summary":"PI-71-066 response to Associated Corrosion Consultants Ltd. concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-066.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-066.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-066","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/PI71066.pdf","body":"<<<PAGE 1>>>\n\nJuly 22, 1971\nMr. H. M. Armstrong, P. Eng.\nAssociated Corrosion Consultants Ltd.\n343 Eleventh Avenue, SW.\nCalgary 3, Alberta\nCanada\nDear Mr. Armstrong:\nThank you for your letter expressing concern about the qualifying of personnel for corrosion\ncontrol work. You will be happy to know that the Office of Pipeline Safety has no plans for\nqualifying natural gas pipeline personnel for this type work. The gas pipeline operator will be\nresponsible for employing qualified personnel, or consultants, for this type work just as he is\nresponsible for making sure of the abilities of all employees to perform their respective jobs in a\nproper manner.\nEnclosed for your information is a copy of Part 192, Minimum Federal Safety Standards for the\nTransportation of Natural and Other Gas by Pipeline (including the recently issued subpart on\ncorrosion control).\nAgain, thank you for your interest. I trust that the above information will be to your liking as it\ndoes not seem to be inconsistent with the thoughts in your letter.\nSincerely,\nJoseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\ndal\\192\\457\\71-07-22\n1\n\n<<<PAGE 2>>>\n\nJune 14, 1971\nThe Secretary of Transportation,\nOffice of Pipeline Safety,\nWashington, D.C. 20590\nU.S.A.\nAttention: Mr. W.C. Jennings,\nActing Director _\nDear Sir:\nRe: 49 CFR Part 192 -\nMinimum Federal Safety Standards\nfor Gas Pipelines - Requirements\nfor Corrosion Control\n_\nAs a Canadian, I appreciate that most of the standard you are about to\nadopt will be seriously considered for adoption here in Canada. Consequently, I feel obliged to\ncomment.\nAs a liscensed [sic] professional engineer in Canada, I am concerned not so\nmuch with the scope of your proposed standard as I am with the qualifications of those\nresponsible for implementing it.\nYou refer to the use which has been made of the National Association of\nCorrosion Engineers Standard RP-01-69.\nYour Standard reads in part as follows:\n192.457 (b) \"Each cathodic protection system must be designed and installed by, or\nunder the direction of, a person qualified by experience and training in\ncorrosion control methods.\"\ndal\\192\\457\\71-07-22\n2\n\n<<<PAGE 3>>>\n\nand,\n192.481 (b) \"Each cathodic protection survey and installation must be made by or\nunder the direction of a person qualified by experience and training in\ncorrosion control methods.\"\nSooner or later the question will arise as to who is qualified and what\nqualifies a person under this standard.\nYou may also be fully aware of NACE's \"Accreditation Program\" for\n\"Corrosion Specialists\", etc., a copy of which is enclosed for your quick reference.\n- 2 -\nI hope you are also fully aware that NACE is not a professional\nassociation, is not a learned society and is not liscensing [sic] body.\nI am concerned that NACE is maneuvering to place itself in a position to\ndefine who \"qualifies\" to apply your standard.\nI believe that insofar as the public safety is concerned, in matters related to\nengineering, the professional engineering associations are not filling that role quite adequately. I\nwould not like to see the role of the professional engineer usurped by a non-professional group.\nThe only qualification to become a member of the National Association of\nCorrosion Engineers, is payment of a membership fee!\nNACE's \"Accreditation Program\" makes allowance for \"previous\nrecognition\", grandfather clauses, and other consideration designed to enroll non-professionals.\nThis may do a lot for the membership roles of NACE but just may not serve the public interest in\nthe way intended.\nAside from important experience factors involved, it is my opinion that the\nfirst requisite of one qualified to assume direction of the implementation of your standard is that\nhe be a licensed professional engineer, responsible to his professional association, and not to\nNACE.\nI believe your State professional engineering associations, and the public,\nwill agree with me!\ndal\\192\\457\\71-07-22\n3\n\n<<<PAGE 4>>>\n\nAs a matter of interest, in my province of Alberta, cathodic protection\ndesign has been legally declared professional engineering - no others need apply.\nRespectfully submitted,\nASSOCIATED CORROSION CONSULTANTS LTD.\nH.M. Armstrong, P. Eng.\nEncls.\ndal\\192\\457\\71-07-22\n4","truncated":false,"body_characters":4231}