# Grey Forest Utilities — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-74-0123
- **title:** Grey Forest Utilities — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1974-07-05
- **effective on:** Not available
- **summary:** PI-74-0123 response to Grey Forest Utilities concerning 192.1.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0123.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0123.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0123
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-07-05_Grant_192.1-nlmx.pdf
**body:**

<<<PAGE 1>>>

PI-74-0123
Jul 5 1974
Mr. Robert S. Grant
Grey Forest Utilities
P.O. Box 258
Helotea, TX 78023
Dear Mr. Grant:
Thank you for your letter of June 10, 1974, asking whether contracting for service to handle
emergency situations would absolve the utility from responsibility and liability for damages
which may arise after the contractor is notified.
Part 192 of title 49 of the Code of Federal Regulations provides that an operator of a gas pipeline
must perform various tasks in order to comply with Federal gas pipeline safety standards. Part
192 does not prohibit an operator from contracting with another person to provide, on his behalf,
any action required by that Part. However, where action is performed by a contractor on behalf
of an operator, the operator remains responsible for compliance of the action with the standards
contained in Part 192.
Questions of liability for property damage or personal injury resulting from pipeline failures are
outside the jurisdiction of this office. Such questions are a matter of common or statutory law
and should be directed to a counselor-at-law.
We appreciate your interest in pipeline safety.
Sincerely,
Joseph C. Caldwell
Director
Office of Pipeline Safety
192.1 1

<<<PAGE 2>>>

Sep 27 1974
Mr. Donald H. Ernest
Director, Pipeline Safety
Indiana Public Service Commission
901 State Office Building
Indianapolis, IN 46204
Dear Mr. Ernest:
This responds to your letter of September 13, 1974, requesting our interpretation of a matter
raised by the Indiana Gas Association, Inc. (IGA).
IGA is concerned about a requirement in 49 CFR Part 192 that inspections must be performed "at
intervals not exceeding one year." Where an inspection is performed on June 1 of a given year,
IGA asks if the next inspection must be performed on May 31 of the following year.
The phrase "at intervals not exceeding one year" defines the maximum period of time between
inspections, but it does not require that each inspection be performed precisely one year later
than the preceding one. Under the phrase, an inspection may be performed at any time, but must
occur no later than one year after the preceding inspection. Thus, in the example cited by IGA, if
an inspection is performed on June 1, the next inspection must be performed before June 1 of the
following year but may be performed at any time in between.
We trust our response is helpful to you.
Sincerely,
Joseph C. Caldwell
Director
Office of Pipeline Safety
192.1 2
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