{"operation":"document","citation":"PI-83-020","title":"Office of Pipeline Safety Regulations — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1983-11-02","effective_on":null,"summary":"PI-83-020 response to Office of Pipeline Safety Regulations concerning 192.614.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-020.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-020.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-020","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/PI83020.pdf","body":"<<<PAGE 1>>>\n\nDEPARTMENT OF COMMERCE\nMr. Richard L. Beam, Associate Director\nOffice of Pipeline Safety Regulations\nMaterial Transportation Bureau\nDepartment of Transportation\nWashington, D. C. 20590\nDear Mr. Beam:\nI recently received a copy of your memorandum dated September 14, 1983, to Robert L.\nPaullin regarding a request for clarification of Section 192.614(b)(4). I was shocked to learn that\nthis memorandum completely contradicted a position your office took on this matter in June,\n1983. This turnaround concerns me greatly because the credibility of the Office of Pipeline Safety\nRegulation has been seriously questioned by myself and many of my state pipeline safety\ncolleagues. I would expect that any verbal communication of positions would carry the same\nweight or importance as any written position.\nBeing a strong supporter of the Federal/State partnership in pipeline safety, I believe we\nmust all work together to accomplish the task of fulfilling our responsibilities under the\nappropriate Federal and State pipeline safety laws. I would encourage your office to establish\nprocedures to inform interested persons of actions your office intends to take regarding inquiries\nfrom those interested people prior to circulating such material throughout the country. This\nshould help ensure that the issue being addressed was completely understood.\nI do not believe my June 17, 1983, letter to Mr. Edward Ondak regarding Section\n192.614(b)(4) was properly characterized or addressed in your September 4, 1983, answer to Mr.\nPaullin's request for clarification. I am willing to discuss this matter with you or your staff and if\nadditional information or further clarification is required, I will be pleased to work with you.\nI would appreciate your consideration in the matter and will indicate that we are not\nattempting to weaken the intent of the regulations but are recognizing that damage prevention\nprograms are different from state to state. The Michigan damage prevention legislation (1974 PA\n53) and the one call communication system (MISS DIG) is the heart of the damage prevention\nprogram in Michigan. This program, together with the cooperation of excavators and various\nutilities, has operated in an effective and efficient manner and it is my desire to see that continue.\nVery truly yours,\nMichael J. Kidd, Supervisor\nOffice of Gas Operations\nDB\nC:\\WP51\\INTERPRT\\192\\614\\83-11-02\n1","truncated":false,"body_characters":2406}