# Vaden, Eickenroht, Thompson, Bednar & Jamison — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-82-008
- **title:** Vaden, Eickenroht, Thompson, Bednar & Jamison — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1982-05-14
- **effective on:** Not available
- **summary:** PI-82-008 response to Vaden, Eickenroht, Thompson, Bednar & Jamison concerning 192.273.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-008.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-008.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-008
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1982/PI82008.pdf
**body:**

<<<PAGE 1>>>

May 14, 1982
Mr. Jennings B. Thompson
Vaden, Eickenroht, Thompson, Bednar & Jamison
Attorneys at Law
One Riverway, Suite 2420
Houston, TX 77056
Dear Mr. Thompson:
Administrator Ray Barnhart, Federal Highway Administration, has asked us to respond to your
letter of April 12 to him which was accompanied by a letter of April 5 from Major Butler
concerning the SURE-LOCK mechanical joint.
Specifically, Mr. Butler's letter requested a review of test data from Southwestern Laboratories to
determine whether or not the joint complies with §192.273 of Part 192, Title 49 of the Code of
Federal Regulations, a general safety standard for joining pipe by means other than welding. The
report from Southwestern Laboratories includes data on hydrostatic tests and tensile tests with
Grade B ERW pipe, and states that the test results meet American Petroleum Institute
requirements. It appears that the connection is capable of producing a joint that can withstand the
contraction and expansion forces and external and internal loads mentioned in §192.273(a), and
that it is gastight as required by §192.273(b). However, actual compliance with §192.273 would
depend on proper installation of the connection by a pipeline operator or his contractor under field
conditions, a matter which we cannot judge based upon the test results alone.
Our determination whether the mechanical joint meets §192.273 is not necessary for Mr. Butler to
market the product. This standard is written in performance language, allowing the pipeline
operator flexibility in choosing the best joining methods to achieve pipeline safety. It is not our
policy to endorse proprietary methods or products that meet the applicable requirements of the
Federal standards. The selection and use of particular joining methods are ultimately the pipeline
operator's responsibility.
We hope this answers your request. If you need further clarification of the Department's pipeline
safety regulations or their enforcement, you may wish to contact Melvin A. Judah, Acting
Associate Director for Pipeline Safety Regulation, Materials Transportation Bureau (MTB),
telephone number
202-426-2392, or Robert F. Aubry, Chief of the MTB Southwest
dal\192\273\82-05-14
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<<<PAGE 2>>>

Regional Office of Operations and Enforcement, telephone number 713-226-5476.
Sincerely,
Howard Dugoff
dal\192\273\82-05-14
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