{"operation":"document","citation":"PI-92-017","title":"Ira Jane Hurst & Associates — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1992-04-15","effective_on":null,"summary":"PI-92-017 response to Ira Jane Hurst & Associates concerning 199.7.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1992/PI92017.pdf","body":"<<<PAGE 1>>>\n\nApril 15, 1992\nMs. Ira Jane Hurst\nIra Jane Hurst & Associates\nP.O. Box 3162\nLafayette, LA 70502\nDear Ms. Hurst:\nThis is in response to your letter of February 6, 1992, to Mr.\nLamar Allen, Department of Transportation, requesting guidance\nconcerning the anti-drug plan requirements for pipeline operators\nsubject to Research and Special Programs Administration (RSPA)\nPart 199.\nYour correspondence indicated that your firm had noted some\ndiscrepancy among several states with regard to their\ninterpretation and enforcement of the Part 199 drug testing\nregulations. This discrepancy was also noted among inspectors\nwithin a particular state. You indicated that your firm had\ndeveloped an anti-drug plan format which was used for a client\nwho has more than one company located in different regions. Both\ncompanies had the same identical plan and in one case an\ninspector found the plan sufficient and in the other region it\nwas found to be inadequate and did not meet the RSPA\nrequirements.\nYou requested this office review your anti-drug plan with regard\nto comments noted on a pipeline operator's plan and comments from\na state inspector. This office does not review nor do we approve\nanti-drug plans for pipeline operators or consortiums. Each\nstate that has adopted Part 199 has established inspection\ncriteria and enforcement policy with regard to drug testing and\nplans. Because the inspection criteria and inspection policy may\nvary somewhat from state to state, some states may perform more\nrigorous inspections. We provide latitude for states to develop\ntheir own inspection program and therefore, there may be some\nvariations between states in the stringency of enforcement.\nA cursory review of the anti-drug plan you submitted for the\nparticular pipeline operator in question appears to have some\ndeficiencies that are not consistent with the requirements of\nPart 199. If the anti-drug plan was formulated using the Federal\nAviation Administration (FAA) criteria as indicated in your\ncorrespondence, this may account for some of the deficiencies as\ntheir drug criteria is somewhat different from RSPA's\nrequirements.\ndal\\199\\7\\92-04-15\n1\n\n<<<PAGE 2>>>\n\n2\nThank you for your inquiry. Please let me know if you need any\nmore information about our drug testing requirements.\nSincerely,\nRichard L. Rippert\nDrug Compliance Coordinator\nOffice of Pipeline Safety\nEnforcement\ndal\\199\\7\\92-04-15\n2","truncated":false,"body_characters":2410}