Lissie Corporation — Pipeline Safety Interpretation

Page 1March 31, 1992 Mr. Edman R. Zink President Lissie Corporation 428-D Petroleum Center 900 NE Loop 410 San Antonio, TX 78209 Dear Mr. Zink: This is in response to your letter of March 17, 1992, to Mr. Richard L. Rippert, Alcohol and Drug Program Manager for the Office of Pipeline Safety, Research and Special Programs Administration (RSPA), requesting guidance on whether functions your corporation performs would subject your employees to the drug testing provisions under Part 199. The RSPA drug testing regulations are applicable to employees who perform on a pipeline or an LNG facility an operation, maintenance, or emergency-response function that is regulated by 49 CFR Parts 192, 193, or 195. As set forth in 49 CFR 192.1, Part 192 does not apply to the onshore gathering of gas outside of the following areas: a. An area within the limits of any incorporated of unincorporated city, town, or village. b. Any designated residential or commercial area such as a subdivision, business or shopping center, or community development. If your gathering line system is not in any of the areas set forth above, your gathering line system is not subject to Part 192 or the drug testing regulations in Part 199. Thank you for your inquiry. testing requirements. Please let me know if you need any more information about our drug Sincerely, Cesar De Leon Director Regulatory Programs Office of Pipeline Safety dal/199.3/Gathering 92-03-31#