{"operation":"document","citation":"PI-73-020","title":"Alemda Welding & Inspection Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-07-25","effective_on":null,"summary":"PI-73-020 response to Alemda Welding & Inspection Company concerning 192.105.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-020.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-020.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-020","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/PI73020.pdf","body":"<<<PAGE 1>>>\n\nMr. B. H. Clements\nAlemda Welding & Inspection Company\nP. O. Box 45872\nHouston, Texas 77045\nDear Mr. Clements:\nYour letter of July 2, 1973, addressed to our Houston Office has been refereed to this Office for\nreply. By it you forwarded a letter form the Mechanical Design and Fabrication Subgroup of the\nASME asking whether the phrase \"is determined\" in §192.105(a) makes the section mandatory.\nIn pertinent part, §192.105(a) reads: \"The design pressure for steel pipe is determined in\naccordance with the following formula: . . . .\" As with the definitions in §192.3, the words \"shall\"\nor \"must\" need not appear to make the paragraph regulatory in nature. The words in question are\nused in the expository sense and the paragraph is definitional in nature. For clarity and\norganization the requirement was placed in Subpart C, but it could have been in §192.3 where as\na definition it would have read: \"Design pressure for steel pipe means that pressure determined in\naccordance with the following formula:....\"\nAs stated in §192.101, Subpart C prescribes minimum requirements for the design of pipe. If the\nformula of §192.105(a) is not used, the requirements are not being met. Whenever design\npressure for steel pipe must be calculated for use in connection with any of the Federal gas\npipeline safety standards, it must be determined as a regulatory matter in accordance with the\nformula given in §192.105(a). Any substitution of expressions which are at variance with those\ngiven in the formula will not result in values for design pressure which can be used for purposes of\nthe regulations.\nIf you have further questions, please call on us.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\105\\73-07-25\n1","truncated":false,"body_characters":1773}