{"operation":"document","citation":"PI-77-012","title":"Product Engineering ACF Industries, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-05-13","effective_on":null,"summary":"PI-77-012 response to Product Engineering ACF Industries, Inc. concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-012.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-012.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-012","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/PI77012.pdf","body":"<<<PAGE 1>>>\n\nACF INDUSTRIES\nApril 18, 1977\nDirector, Office of Pipeline Safety\nDepartment of Transportation\n400 7th Street S.W.\nWashington, D.C. 20590\nSubject: Title 49 of the Code of Federal Registrations, Part 192\nDear Sir:\nW-K-M is a manufacturer of valves which are used in all types of industrial, pipeline and oilfield\napplications. Occasionally we have a customer who requires certification of our valves\ncompliance to the above regulation. This is a simple matter for valves 2\" and larger. Our concern\nis that we do not know the position of the D.O.T. for valves smaller than 2\" (especially NPT\nthreaded end). These sizes are not within the scope of any of the standards listed in part\n192.145(a), nor is there any equivalent standard for these sized. Your response to the following\nquestions would be greatly appreciated.\n1. Are valves smaller than 2\" within the scope of CFR Title 49, Part 192?\n2. If yes to above, what is considered an equivalent applicable standard?\n3. If no to above, what requirements must be met to assure conformance to CFR 49, Part\n192?\nI wish to thank you in advance for your prompt attention to this matter.\nSincerely,\nCharles C. Partridge, P.E.\nProduct Engineering\nEngineering & Research\nDAL\\192\\3\\77-04-18\n1\n\n<<<PAGE 2>>>\n\nMay 13, 1977\nMr. Charles C. Partridge\nProduct Engineering\nACF Industries, Inc.\nP.O. Box 2117\nHouston, Texas 77001\nDear Mr. Partridge:\nThis responds to your letter of April 18, 1977, in which you ask about the applicability of 49 CFR\n192.145 to valves smaller than 2 inches.\nThe Materials Transportation Bureau's position is that Section 192.145 is applicable to all sizes of\nvalves used in \"pipelines\" or \"pipeline facilities\" as those terms are defined in Section 192.3.\nPublished specifications do not exist for all types and sizes of valves that are manufactured.\nHowever, there are certain basic safety design features that can be applied to all valves. In\nSection 192.145, the word \"equivalent\" is used in the sense of providing an equivalent level of\nsafety. Thus, although the specifications listed in Section 192.145 do not cover all sizes and types\nof valves, the valves not covered must at least meet the applicable level of safety prescribed by the\nlisted specifications.\nI trust this satisfactorily responds to your inquiry. If I can be of further assistance, please let me\nknow.\nSincerely,\nCesar DeLeon\nActing Director\nDAL\\192\\3\\77-04-18\n2\n\n<<<PAGE 3>>>\n\nOffice of Pipeline\nSafety Operations\nDAL\\192\\3\\77-04-18\n3","truncated":false,"body_characters":2487}