{"operation":"document","citation":"PI-76-0101","title":"Pipeline Safety Interpretation PI-76-0101","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-01-22","effective_on":null,"summary":"PI-76-0101 concerning 192.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0101.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0101.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0101","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/g76-01-22_CLAPSADDLE_192.1-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-76-0101\nJanuary 22, 1976\nMr. L. D. Clapsaddle\nAssistant Regional Administrator\nfor Housing Management\nDepartment of Housing and\nUrban Development\n1100 Commerce Street\nDallas, Texas 75202\nDear Mr. Clapsaddle:\nYour letter of November 4, 1975, requests clarification of the responsibility for compliance with\ncertain Federal gas pipeline safety standards contained in 49 CFR Parts 191 and 192 by a housing\nproject owner who owns gas pipelines in the project which are subject to those standards. The\npipelines involved are operated by a local gas distribution company which sells gas to tenants\nthrough individual meters owned by the gas company. Specifically, you ask whether the project\nowner, the gas company, or both are required by law to comply with certain safety standards.\nAs your letter indicates, we advised Mr. Sterling Cockrill of your Little Rock office by letter of\nAugust 18, 1975, that in situations like the one you describe, if the project owner owns the gas\npipelines involved, that owner would be responsible for compliance with applicable safety\nrequirements as well as the gas distribution company who operates the pipelines. That opinion\nwas based on Sec. 8 of the Natural Gas Pipeline Safety Act of 1968 (49 USC 1677) which\nrequires that each person who owns or operates pipeline facilities must comply with applicable\nregulations.\nWe did not intend to imply that certain regulations are binding on the owner of facilities while\nothers are binding on the person operating the facilities. Under Section 8 of the Act, we view the\nobligation to comply with applicable regulations as a single responsibility which must be met by\neither the owner of facilities or the person who operates them. Compliance by either person\nsatisfies the entire obligation.\nAs a practical matter, however, because the regulations in Parts 191 and 192 are directed toward\ncompliance by persons in the gas pipeline transportation business who operate pipeline facilities,\nthe need to enforce compliance against an owner who does not operate facilities has never arisen.\nWe trust this satisfactorily responds to your inquiry.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations","truncated":false,"body_characters":2214}