{"operation":"document","citation":"PI-96-016","title":"State of Alaska Department of Labor — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1996-07-22","effective_on":null,"summary":"PI-96-016 response to State of Alaska Department of Labor concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-016.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-016.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-016","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1996/PI96016.pdf","body":"<<<PAGE 1>>>\n\nJuly 22. 1996\nMr. Tom Cashen\nCommissioner\nState of Alaska\nDepartment of Labor\nP.O. Box 21149\nJuneau, Alaska 99802\nDear Mr. Cashen:\nThank you for your letter requesting clarification on preemption and jurisdictional issues\nbetween the U.S. Department of Transportation’ s Office of Pipeline Safety (OPS) and the\nAlaska Occupational Safety and Health Program (AKOSH) over certain worker safety issues on\nthe Trans-Alaskan Pipeline System (TAPS).\nIn your letter you stated that some of the pump stations have topping units that produce turbine\nfuel from the crude oil flowing through the pipeline and that this fuel is used to operate pump\nstation pumping systems. Although the topping units are located within the fenceline of TAPS\npumping stations and are an essential part of the pipeline facility as configured by the owners of\nTAPS, the hazardous liquid pipeline safety regulations in 49 C.F.R. 195 do not address the\nsafety issues inherent in refinery processes such as topping units. Therefore, the regulations of\nAKOSH as they apply to these topping units and the associated vapor recovery units and fuel\nstorage tanks do not conflict with and are not preempted by the federal pipeline safety\nregulations.\nIn addition, the federal pipeline safety regulations do not preempt the AKOSH regulations on\nworker safety issues, including noise levels, crane operations, and protection on open-sided\nplatform as referred to in your letter.\nIf you have any questions, please contact Jon Strawn, OPS’ Alaska representative, at 907-271-\n4373 or L.E. Herrick, OPS headquarters, at 202-366-5523.\nSincerely,\nRichard D. Huriaux, P.E.\nDirector, Technology & Regulations\nR. Herrick:brw-(202)366-4395-07/10/96\nCC: DPS-11,10,20,2,1\nRegion Mailing, State Mailing\n[b:\\akosh.int]","truncated":false,"body_characters":1776}