{"operation":"document","citation":"PI-73-018","title":"Lineguard, Inc — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-06-26","effective_on":null,"summary":"PI-73-018 response to Lineguard, Inc concerning 192.321.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/PI73018.pdf","body":"<<<PAGE 1>>>\n\nJune 26, 1973\nMr. Gordon H. Allen\nPresident, Lineguard, Inc.\nP.O. Box 426\nWheaton, Illinois 60187\nDear Mr. Allen:\nYour letter of May 23, 1973, asks whether detectable marking tape, such as your product with\nthe trade name \"Lineguard,\" qualifies as a means of locating plastic pipe under §192.321(e) of the\nFederal natural gas pipeline safety regulations.\nSection 192.321(e) requires that plastic pipe that is not encased must have an electrically\nconductive wire or other means of locating the pipe while it is underground. You question\nwhether the marking tape qualifies as \"other means\" within the wording of the regulation.\nAs you describe it, the detectable marking tape is made of long-life 2-inch wide plastic that is\nsuitably colored and inscribed. The tape is installed above plastic pipe at a depth of 4 to 10 inches\nbelow the surface of the ground where it serves the dual purpose of warning and locating.\nDetectable marking tape having the physical characteristics and installed as you have described it\nmeets the requirements for \"other means\" of locating pipe in accordance with the requirements of\n§192.321(e).\nThe Federal gas pipeline safety regulations are performance type standards rather than\nspecification standards. In general such regulations state an objective requirement but leave the\nspecific means of compliance to the selection of the operator. Thus, with regard to locating\nplastic pipe, there may conceivably be many means other than plastic tape, and it would be\nimpractical to include detailed specifications for each means within the regulation. Therefore, it\nwould not be appropriate to amend\ndal\\192\\321\\73-06-26\n1\n\n<<<PAGE 2>>>\n\n2\n§192.321(e) as you have suggested to make specific provision for your tape even though it\nappears to meet the present standard.\nThank you for informing us about your product. If we may be of further assistance, please call on\nus.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\321\\73-06-26\n2","truncated":false,"body_characters":1998}