{"operation":"document","citation":"PI-89-024","title":"Hewlett-Packard Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1989-11-21","effective_on":null,"summary":"PI-89-024 response to Hewlett-Packard Company concerning 199.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-024.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-024.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-024","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/76276/pi-89024.pdf","body":"<<<PAGE 1>>>\n\nNovember 21, 1989\nMr. James C. Powell\nHewlett-Packard Company\nP. O. Box 301\nLoveland, Colorado 80537\nDear Mr. Powell:\nIn your letter of November 3, 1989, to Cesar De Leon you asked whether turning valves to switch\nyour pipeline from one source of gas to another would make the person who turns the valves subject to\ndrug testing under Part 199.\nA person is subject to drug testing under Part 199 when he or she performs on a pipeline an operating,\nmaintenance, or emergency-response function regulated by the gas pipeline safety standards in Part\n192. Since switching the source of gas is an operating function, we examined Part 192 to see whether\nthis function is regulated. Although Part 192 has no rule governing this function specifically,\n§192.605(a) requires each operator to include in its operating and maintenance plan \"instructions for\nemployees covering operating . . . procedures during normal operations.\" Because normal operations\ninclude the switching of gas sources, this switching function should be covered by procedures in the\noperating and maintenance plan for your pipeline. Therefore, the function of switching the source of\ngas is an operating function regulated by Part 192, and the person who performs that function is\nsubject to drug testing.\nPlease let me know if I can be of any further assistance regarding our drug testing rules.\nSincerely,\nGeorge W. Tenley, Jr.\nActing Director\nOffice of Pipeline Safety\ndal/199.1\n89-11-21","truncated":false,"body_characters":1467}