{"operation":"document","citation":"PI-94-018","title":"Pipeline Safety Interpretation PI-94-018","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1994-04-29","effective_on":null,"summary":"PI-94-018 concerning 199.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/76361/pi-94018.pdf","body":"<<<PAGE 1>>>\n\nApril 29, 1994\nThis is in response to your correspondence of January 11, 1994, requesting an interpretation\nregarding functions performed by Conoco Pipeline “ call-out” personnel and whether these\nfunctions are covered under the Department of Transportation, Research and Special Programs\nAdministration (RSPA) drug testing regulations at 49 CFR 199.7(a). Your correspondence\nindicates these call-out personnel are located in close proximity to the pump stations and provide\na convenience factor for our full-time operating personnel.\nYou stated that instead of Houston Oil Movements calling a technician who is 3-hours from the\npump station, they contact the call-out employee to go to the pump station for a preliminary\ninvestigation. If the problem is minor, i.e., resetting the alarm, the call-out will reset and let\nHouston know. If the problem is something other than that or will not go away, then the call-out\nwill call the technician or the area supervisor and turn the problem over to them. Other job\nfunctions include doing nothing but observing and reporting problems to others; weekly pump\nstation checks; pump sump - usually this is into the mainline; check CDR injection - might purge\nout the system; resets alarm - if alarm will not reset, will call appropriate personnel; and will not\nperform emergency response.\nBased on the information you provided it would appear that the call-out employees do perform\noperation, maintenance, or emergency-response functions on the pipeline and they would be\nregulated under the regulations contained in 49 CFR Parts 192, 193, or 195.\nThank you for your inquiry. Please let me know if you need additional information about our\ndrug testing requirements.\nSincerely,\nRichard L. Rippert\nDrug and Alcohol Program Manager\nOffice of Pipeline Safety\nCompliance\ndal/199.1\n94/04/29","truncated":false,"body_characters":1840}