{"operation":"document","citation":"PI-74-018","title":"Tennessee Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-03-11","effective_on":null,"summary":"PI-74-018 response to Tennessee Public Service Commission concerning 192.63.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/PI74018.pdf","body":"<<<PAGE 1>>>\n\nMar 11 1974\nMr. John Searcy\nEngineering Division\nTennessee Public Service Commission\nCordell Hull Building\nNashville, TN 37219\nDear Mr. Searcy:\nThis is in response to your letter of February 22, 1974, regarding an Office of Pipeline Safety\ninterpretation of 49 CFR 192.63 which states that \"The intent of the regulation is that the product\nbe clearly identified from point of manufacture to installation. In general, a marking on a package\nwould not serve to identify a product out of the package prior to installation.\"\nYou point out that Section 11.lb of API Standard 5L, 1970 allows bundle marking of pipe in sizes\n1.900 inch OD and smaller, which does not meet the intent of the regulation if individual pipe\nlengths are removed from a bundle and installed separately. Then, you ask whether the intent of\n§192.63 prevails over Section 11.lb of API Standard 5L to require marking of individual lengths\nof pipe removed from a bundle and installed separately.\nUnder §192.63, pipe must be clearly identified from point of manufacture to installation. In the\ncase of bundle marked pipe, this requirements is satisfied where the bundle is used at a single\ninstallation. However, if lengths of pipe are taken out of the bundle and used at separate\ninstallations, each length removed must be marked exclusive of the bundle marking to comply\nwith the requirement.\nWe trust that this has answered your particular question.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192.1-b\\63\\74-03-11\n1","truncated":false,"body_characters":1521}