{"operation":"document","citation":"PI-94-031","title":"Central Plastics Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1994-10-17","effective_on":null,"summary":"PI-94-031 response to Central Plastics Company concerning 192.273.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-031.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-031.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-031","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94031.pdf","body":"<<<PAGE 1>>>\n\nOctober 17, 1994\nJim Inhofe\nDirector of Engineering\nCentral Plastics Company\nP.O. Box 3129\nShawnee, OK 74801\nDear Mr. Inhofe:\nThank you for your letter of July 28, 1994, regarding the specimen joint that an individual must\nmake in qualifying to join plastic pipe. Under 49 CFR 192.285(b)(1), the specimen joint must be\n“ visually examined during and after assembly or joining and found to have the same appearance as\na joint or photographs of a joint that is acceptable under the procedure.” You asked whether this\nrequirement can be met on electrofusion joints that do not have a “ pop-up” or other device to\nindicate a proper joint.\nAfter passing visual inspection, electrofusion specimen joints are physically tested for integrity (49\nCFR 192.285(b)(2)). So the preliminary visual inspection merely serves to screen out visibly\nunacceptable joints from further examination. A device to indicate a proper joint is unnecessary\nfor this purpose. Screening can be accomplished by inspecting the joint for any visible\nirregularities, including incorrect insertion depth and misalignment. Moreover, such a device is\nunnecessary for safety under 49 CFR 192.285(b), because even if an unacceptable joint passes\nvisual inspection, it will be rejected by the physical test.\nAdditionally, a device to indicate a proper joint is unnecessary for adequate inspection of joints\nunder 49 CFR 192.273(c). Under this standard, each electrofusion joint in a pipeline must be\ninspected for compliance with applicable requirements of 49 CFR Part 192, Subpart F. An\nadequate inspection is provided by looking for visible joint irregularities, by observing control\ninstruments during the joining process, and by confirming that proper joining procedures are\nfollowed.\nPlease let me know if you have any further concerns about the Department’ s plastic pipe\nregulations. We will distribute this interpretation to all regional and state offices.\nSincerely,\nCesar De Leon\nDeputy Associate Administrator\nfor Pipeline Safety\ndal/192.273\n94-10-17\n\n<<<PAGE 2>>>\n\nCENTRAL\nNovember 3, 1994\nMEMO TO: Richard Conley - Kerotest\nFrank Volgstadt - Perfection\nJim VanHoutte - Dresser\nLu Lyall - R.W. Lyall Co.\nGene Palermo - Uponor\nTom Walsh - PPI\nMark Sievers - Keller & Heckman\nRichard Sanders - DOT\nTom Cravens - Central Plastics\nBob Sehorn\nBob Shaffer\nRocky Wade\nPhill Pourchot\nClay Hamilton\nTerry Stiles\nBob Pourchot\nFROM: Jim Inhofe\nSUBJECT: Connecticut issue of code requirements for “ Pop Up” visual indicators for\nelectrofusion fittings.\nThe above subject challenge to electrofusion requirements by Mr. Phil Sher of the\nConnecticut Dept. of Utility Control has received the attached interpretation from the offices of\nDOT.\nAs you will note by Mr. DeLeon’ s letter, it is planned that his interpretation will be\ndistributed to those offices affected.\nThis opinion is a direct result of efforts conducted in the name of the PPI Fuel Gas\nCommittee and a Task Group formed from that committee to address the issue. Much\nappreciation is due Richard Sanders of the DOT/TSI School in Oklahoma City also.\nAt any rate, this opinion to be issued should negate any “ opinions” or other negatives\ncoming forth in the future from Mr. Phil Sher or others who may share his opinion.\nThis should put the issue at rest. If the problem should re-appear from another source or\nthe same one, please advise me. I think we have the proper support to subdue any real negative\neffects should that occur.\nJ. Inhofe\ndal/192.273\n94-10-17","truncated":false,"body_characters":3498}