{"operation":"document","citation":"PI-92-0102","title":"Midwest Pipe Coating, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1992-04-30","effective_on":null,"summary":"PI-92-0102 response to Midwest Pipe Coating, Inc. concerning 192.63.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-0102.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-0102.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-0102","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1992/g92_04_30_Hopkins_192.63_lmx.pdf","body":"<<<PAGE 1>>>\n\nPI-92-0102\nApril 30, 1992\nMr. Tom Hopkins\nVice President\nMidwest Pipe Coating, Inc.\nP.O. Box 127\nSchererville, IN 46375-0127\nDear Mr. Hopkins:\nYour letter of March 31, 1992, requests an interpretation of the gas pipeline safety regulation regarding marking pipe\nand pipeline components, 49 CFR 192.63. You seek clarification of the requirements for marking pipe when you, a\ncoating applicator, apply a protective coating that obliterates the manufacturers' original markings.\nThe intent of the regulation is that the product, pipe, valve, or fitting be clearly identified from manufacture to\ninstallation. Where pipe is coated before installation and the marking is covered, the coated pipe must be marked again\nunless another means of identification permitted by §192.63(a) is used.\nThe pipeline operator is the responsible party for assuring a means to identify each pipeline component until it is\ninstalled. For coated pipe in short term storage or protected storage, a marking on the coating or coating wrapper will\nnormally remain legible until installation. For coated pipe in long term storage, marking is usually maintained by\nstenciling the pipe inside an end.\nWe trust that this responds satisfactorily to your request.\nSincerely,\nCesar De Leon\nDirector, Regulatory Programs\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nMidwest Pipe Coating, Inc.\nP.O. Box 127\nSchererville, Indiana 46375-0127\nMarch 31, 1992\nResearch & Special Programs Administration\n400 7th Street S.W.\nWashington D.C. 20590\nATTENTION: GEORGE TENLEY: ASSOC. ADMIN. FOR PIPELINE SAFETY\nDear Mr. Tenley:\nOur company applies protective coating over the outside of steel pipe that will carry natural gas. The pipe will be\nburied.\nWe are required to mark each piece of pipe with certain data as Pipeline Safety regulations require the\ntransmission and utility companies to have this data on each length of pipe.\nOwner specifications require us to so provide certain information on each length of pipe - they normally\nenumerate the required information and as an added assurance that this is done they add the caveat \"as required by the\nDOT regulation 192.63 titled Marking of Materials.\nThis regulation speaks to the pipe manufacturer’s responsibility for required markings and does not speak\nspecifically to a coating applicators responsibility.\nThe manufacturer does the required marking of a length of pipe: Item \"a\" each length of pipe must be marked\nand item \"b\" indicate size, material and manufacturer and grade item \"d\" each item is identifiable as to type,\nmanufacturer and model.\nThe coating applicator includes all these items in our marking but do not - nor do owners ask us to include:\npressure and temperature ratings. Under this regulation for pipe producers stamping as well as marking is allowable.\nO.D. Coatings will likely obliterate markings and only cover up stampings and we as a secondary processor - not\na pipe producer may cover up some of the producers required markings and are not required to re-establish the\ninformation on the coating. I would guess that \"2.d\" takes care of this wherein it states: \"Specifications or standards\ngiving pressure, temperature and other appropriate criteria be readily available\" which must refer to paperwork,\ncertifications and identification.\nI wonder if the regulations should more clearly define the secondary processors requirements, also the regulations do\nnot specify the location of markings or whether the information is 7 required in more than one location on the pipe.\nWhen we liquid I.D. coat pipe we reproduce the information on the inside of the pipe we coat in the same area\nthe producer marked it — at the end.\nYours truly,\nMidwest Pipe Coating, Inc.\nTom Hopkins, Vice President","truncated":false,"body_characters":3738}