New Associate Administrator for Pipeline Safety

Ms. Stacey Gerard has been officially named as the new Associate Administrator for Pipeline Safety. She was previously named as the Acting Associate Administrator upon Rich Felder's departure from that post.

New Chairman of NAPSR

Mr. Joel E. Kohler, PE, Assistant Director of Pipelines for the State of Louisiana, Office of Conservation, Pipeline Division, was recently elected Chairman of the National Association of Pipeline Safety Representatives (NAPSR). This is the first time that a public official from Louisiana has been elected chairman of this organization. NAPSR was formed in 1982, to set policies, procedure and standards for the gas and liquid pipeline industry across the United States. Membership is comprised of professionals from each state pipeline safety program with participation from the federal Department of Transportation and various trade organizations.

Technical Advisory Committee Appointment

Mr. Kohler has also been appointed by the Secretary of the US Department of Transportation to the National Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC). The THLPSSC is a statutorily mandated advisory committee that advises OPS on proposed safety standards and other safety policies for hazardous liquid pipelines. The committee consists of 15 members representing government, industry, and the public. The committees meet twice a year, usually in May and November. Mr. Rickey Cotton from Mississippi and Mr. John Gawronski from New York are other state Pipleine safety Representatives who also serve on this committee.

Upcoming Seminar

RCP is planning an Operator Qualification Workshop at the Houston offices in October. For more information on the seminar, please contact Bill Byrd at wrbyrd@your-rcp.com or phone 225-229-8080.

THLPSSC Special Briefing and Meeting

The Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will hold a briefing on Thursday, August 24, 2000, at 11:30 a.m. EST and a regular meeting on Monday, September 11, 2000, at 11:30 a.m, to consider two Notices of Proposed Rulemaking (NPRM), "Areas Unusually Sensitive to Environmental Damage" (64 FR 73464) and "Pipeline Integrity Management in High Consequence Areas for Hazardous Liquid Pipelines" (65 FR 21695). Both the briefing and the meeting will be conducted via conference call. Members of the public may attend the meetings at the Department of Transportation, Nassif Building, 400 Seventh Street, SW., Washington, DC 20590. The August 24 meeting is in room 8442 and the September 11 meeting is in room 6200. An opportunity will be provided for the public to make short statements on the topics under discussion. Anyone wishing to make an oral statement should notify Juan Carlos Martinez, (202) 366-1933, not later than August 16, 2000, on the topic of the statement and the time requested for presentation.

FOR FURTHER INFORMATION CONTACT: Cheryl Whetsel, OPS, (202) 366-4431 or Richard Huriaux, OPS, (202) 366-4565, regarding the subject matter of this notice. However, because the THLPSSC requested a delay in its formal review of two proposed rules at the May 2000 meeting and OPS intends to complete action on both rulemakings this year, a meeting is being held in September. The biannual meeting generally held in November for both the THLPSSC and the Technical Pipeline Safety Standards Committee will be postponed until February 2001.

Acquiring a pipeline?

RCP can provide due diligence audits to help you ensure that potential compliance issues have been addressed before the sale is final.

Government Accounting Office Report On Pipeline Safety

In May, 2000, the GAO submitted a report on pipeline safety to Rep. John Dingell of the Committee on Commerce, U.S. House of Representatives. The full report is available for download on RCP's website here. NOTE: the report file is 2,000 kb, so do not attempt to download this report via a slow internet connection such as a phone line. Some items of interest in the report include:

  • in 1999, OPS employed 51 pipeline inspectors, and the states employed about 300
  • hazardous liquid pipelines represent about 7% of the regulated pipeline mileage, but cause 50% of the property damage (liquid spills are costly to clean up and can damage a lot of properly, while gas releases tend to dissipate to the atmosphere).
  • the three most prevalent causes of pipeline accidents are outside force (45%), "other" (25%), and corrosion (15%).
  • the number of "enforcement actions" has risen from 94 in 1990 to 218 in 1998.
  • the % of enforcement actions with fines decreased from 49% in 1990 to 4% in 1998 (the GAO wants to DOT to determine if the reduced emphasis on fines is effective).
  • OPS is emphasizing "system wide inspections", and plans to conduct 8 system wide inspections in 2000 (up from 4 in 1999).
  • OPS is spending more time on construction inspections (546 days in 1999, versus 102 days in 1995).
  • OPS is continuing to address open recommendations from the National Transportation Safety Board.These include items such as pipeline isolation valves, periodic internal inspections of pipelines, and pipeline operator training.

OSHA Policy On Self-Audits

The Occupational Safety and Health Administration (OSHA) has developed a final policy describing the Agency's treatment of voluntary employer self-audits that assess workplace safety and health conditions, including compliance with the Occupational Safety and Health Act (Act). The policy provides that the Agency will not routinely request self-audit reports at the initiation of an inspection, and the Agency will not use self-audit reports as a means of identifying hazards upon which to focus during an inspection. In addition, where a voluntary self-audit identifies a hazardous condition, and the employer has corrected the violative condition prior to the initiation of an inspection (or a related accident, illness, or injury that triggers the OSHA inspection) and has taken appropriate steps to prevent the recurrence of the condition, the Agency will refrain from issuing a citation, even if the violative condition existed within the six month limitations period during which OSHA is authorized to issue citations. Where a voluntary self-audit identifies a hazardous condition, and the employer promptly undertakes appropriate measures to correct the violative condition and to provide interim employee protection, but has not completely corrected the violative condition when an OSHA inspection occurs, the Agency will treat the audit report as evidence of good faith, and not as evidence of a willful violation of the Act. The complete policy can be downloaded from RCP's website here.

Pending Audits?

Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency's latest standards.

Producer-operated OCS Pipelines That Cross Directly Into State Waters

On July 27, 2000 the Minerals Management Service (MMS) issued a Final rule to clarify some unresolved regulatory issues involving the 1996 memorandum of understanding (MOU) on Outer Continental Shelf (OCS) pipelines between the Departments of the Interior (DOI) and Transportation (DOT). It addresses producer-operated pipelines that do not connect to a transporting operator's pipeline on the OCS before crossing into State waters. It is complementary to the final rule published on August 17, 1998, which addressed producer-operated oil or gas pipelines that connect to transporting operators' pipelines on the OCS. The rule also establishes procedures for producer and transportation pipeline operators to get permission to operate under either MMS or DOT regulations governing pipeline design, construction, operation, and maintenance according to their operating circumstances. The new regulation is effective August 28, 2000, and can be downloaded from RCP's website here

New Proposed GAS Reporting Forms

On August 2, the Research and Special Programs Administration (RSPA) published its intention to revise forms RSPA F 7100.2-Incident Report For Gas Transmission and Gathering Systems and RSPA F 7100.2-1-Annual Report For Gas Transmission and Gathering Systems (Docket No. RSPA-98-4957). Comments on this notice must be received on or before October 2, 2000. Comments are invited on:

  1. the need for the proposed collection of information for the proper performance of the functions of the agency, including whether the information will have practical utility;
  2. the accuracy of the agency's estimate of the burden of the proposed collection of information including the validity of the methodology and assumptions used;
  3. ways to enhance the quality, utility and clarity of the information to be collected; and
  4. ways to minimize the burden of the collection of information on those who are to respond, including the use of appropriate automated, electronic, mechanical, or other technological collection techniques.

The notice and proposed forms are available on RCP's website at

www.your-rcp.com/downloads/misc/65 fr 47585.pdf

FOR FURTHER INFORMATION CONTACT: Roger Little by telephone at 202-366-4569, by fax at 202-366-4566, by mail at U.S. Department of Transportation, RSPA, 400 Seventh Street, SW, Room 7128, Washington, DC, 20590, or by e-mail to roger.little@rspa.dot.gov.

Industry Meets with NTSB

The following information was provided to us from the SGA listserver on Operator Qualification Issues:

On July,14 AGA and industry representatives met with Bob Chipkevich, Director of Office of Pipeline and Hazardous Materials Safety and Rod Dyck, Deputy Director – Pipeline Safety from the NTSB. The purpose of the meeting was to brief NTSB on current industry implementation efforts on the DOT Operator Qualification (OQ) Rule and, if necessary, discuss the content of the Rule. This was accomplished primarily by giving the NTSB staff an overview of where operators and contractors currently are in preparing their plans, the development of consortiums, the work with regional associations, the American Public Gas Association (APGA), the DOT Transportation Safety Institute-led Pipeline Employee Performance Group and individual state safety representatives. The meeting was cordial and concluded with AGA offering to set-up further briefings with the agency, perhaps with some of the smaller operators in attendance. The full text of the announcement can be downloaded on RCP's website at http://www.your-rcp.com/downloads/misc/NTSB Meeting.htm.

DOT Inspection Areas of Emphasis

Some DOT inspectors have indicated that the DOT is emphasizing 4 key areas in their current inspections. These are:

  1. Pressure test records / documentation of MOP
  2. Follow up to abnormal conditions
  3. Smart pig results and follow up
  4. Damage prevention programs

Operators are reporting that they have received warnings in these areas, even though they have passed previous audits with no concerns. Operators are encouraged to look at their programs in these 4 areas, and ensure that they are in compliance with the applicable regulations.

Pipeline Safety Regulations

The October, 1999 revision of the Pipeline Safety Regulations Part 190-199 is available from TSI. You can request a free copy from TSI, Pipeline Safety Division, (DTI-60), MPB Bldg., RM 330, PO Box 25082. OKC, OK 73125-5050. Additional copies are $10.00.

Help Wanted

Know someone with regulatory expertise who is interested in full or part time work? Our recruiting coordinator would be glad to get their resume! Have them sent to marilyn@your-rcp.com, or FAX to 713-655-8083.

Visit Regulatory Compliance Partners on the Web at

http://www.your-rcp.com

or give us a call at 1-888-RCP-X-YES to see what we can do for you.

Ongoing Resources

These articles are maintained and updated as new information becomes available.

Last Updated: October 2026

Regulatory Watch: Key Dates & Deadlines

Welcome to Regulatory Watch! In this monthly update, we’ll keep you informed on proposed rule comment periods, effective dates, and upcoming deadlines for various compliance requirements.

2137-AF63Proposed Rule Stage

Administrative Rulemaking Regulatory Procedures

Proposed
Final
Implementation
Regulatory WatchImplementation Stage

All Liquid HCA segments capable of ILI § 195.452(n)

Proposed
Final
ImplementationJul 2, 2040
2137-AF45Proposed Rule Stage

Amendments to Liquefied Natural Gas Facilities

Proposed
Final
Implementation
2137-AF61Final Rule Stage

Cost Recovery for Siting Reviews for LNG Facilities

Proposed
Final
Implementation
2137-AF51Final Rule Stage

Gas Pipeline Leak Detection and Repair

Proposed
Final
Implementation
Regulatory WatchImplementation Stage

Gas Transmission: Assessments Outside HCAs § 192.710

Proposed
Final
ImplementationJul 3, 2034
2137-AF37Proposed Rule Stage

Oil Spill Response Plans, Accident Notifications, Inspections and Investigations and other Miscellaneous Pipeline Safety Changes

Proposed
Final
Implementation
2137-AF52Proposed Rule Stage

Pipeline Operational Status

Proposed
Final
Implementation
2137-AF44Proposed Rule Stage

Repair Criteria for Gas and Hazardous Liquid Pipelines

Proposed
Public comments ClosedCloses Sep 8, 2026
Final
Implementation
2137-AF60Proposed Rule Stage

Safety of Carbon Dioxide and Hazardous Liquid Pipelines

Proposed
Final
Implementation
2137-AF53Final Rule Stage

Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives

Proposed
Final
Implementation

Sprint I & II Update

To further the Administration’s deregulatory policies, PHMSA has published in today’s Federal Register twenty-eight (28) separate rulemaking actions affecting the pipeline safety regulations (PSR; Parts 190-199). Click here to access the documents.

Rulemaking Description Stage Code
Pipeline Safety: Rationalize Special Permit Conditions PHMSA proposes to amend its special permit procedures to ensure permit conditions are directly tied to the specific pipeline safety regulations being waived. NPRM 49 CFR Part 190
Pipeline Safety: Rationalize Calculation of Regulatory Filing and Compliance Deadlines PHMSA will clarify that regulatory filing and compliance deadlines falling on weekends or Federal holidays automatically move to the next business day. DFR 49 CFR Part 190
Pipeline Safety: Adjust Annual Report Filing Timelines PHMSA will amend annual reporting requirements to move the gas pipeline annual report submission deadline from March to June. DFR 49 CFR Part 191
Pipeline Safety: Property Damage Definition for Incident Reporting PHMSA will clarify incident reporting property damage calculations for gas pipelines and update hazardous liquid accident reporting thresholds using inflation-adjusted criteria. DFR 49 CFR Parts 191 & 195
Pipeline Safety: Exception for In-Plant Piping Systems PHMSA proposes to clarify that in-plant piping systems are not subject to federal pipeline safety regulations. NPRM 49 CFR Part 192
Pipeline Safety: Codify Enforcement Discretion on Incidental Gathering Lines PHMSA proposes to codify enforcement discretion clarifying that restrictions on the historical incidental gathering line exemption apply only to newly constructed lines. NPRM 49 CFR Part 192
Pipeline Safety: Eliminate Burdensome Coating Assessment Deadlines PHMSA proposes to replace prescriptive deadlines for coating damage assessments and remediation with a requirement that activities be completed before the pipeline is placed in service. NPRM 49 CFR Part 192
Pipeline Safety: Atmospheric Corrosion Reassessment for Pipeline Replacements PHMSA proposes to remove the 3-year reassessment interval following replacement of atmospheric corrosion defects and allow use of the standard 5-year reassessment interval. NPRM 49 CFR Part 192
Pipeline Safety: Harmonize Class Change Pressure Test Requirements PHMSA proposes to reduce the minimum pressure test duration following certain class location changes from 8 hours to 4 hours, aligning with existing Subpart J requirements. NPRM 49 CFR Part 192
Pipeline Safety: Clarify MAOP Reconfirmation Testing Records PHMSA will issue a technical correction clarifying that operators may use pre-1970s pressure test records when reconfirming MAOP under §192.624. Final Rule 49 CFR Part 192
Pipeline Safety: Remote Sensing Technologies for ROW Patrols PHMSA will explicitly allow right-of-way patrols to be conducted using unmanned aircraft systems, satellites, and other remote sensing technologies. DFR 49 CFR Parts 192 & 195
Pipeline Safety: Technical Standards Updates and Amendments PHMSA will update incorporated standards and make technical amendments in response to an industry petition for reconsideration. Final Rule 49 CFR Part 192
Pipeline Safety Program: Update of Standards Incorporated by Reference PHMSA issued multiple direct final rules updating incorporated industry consensus standards used throughout Parts 192 and 195, replacing outdated editions with current versions. Multiple DFRs 49 CFR Parts 192 & 195

The following is a summary of the 40 rulemakings that PHMSA published in the Federal Register on April 24, 2026. If any adverse comment is received to a DFR PHMSA must rescind the rule and repropose. Click here to access the documents.

Rulemaking Description Stage Code
Pipeline Safety and Hazardous Materials Safety: Amendments to PHMSA Procedural Regulations PHMSA proposed miscellaneous amendments to procedural regulations governing informal rulemaking for both pipeline safety and hazardous materials programs. NPRM 49 CFR Part 190
Pipeline Safety: Interpretation Request Procedures PHMSA amended interpretation procedures to require publication of interpretation requests on its website and provide an opportunity for public comment. Final Rule 49 CFR Part 190
Pipeline Safety: Declaratory Order Procedures PHMSA established formal procedures for issuing declaratory orders through a new section in Part 190. Final Rule 49 CFR Part 190
Pipeline Safety: Consent Orders PHMSA clarified that consent agreements may be used to resolve enforcement actions, including cases involving civil penalties. Final Rule 49 CFR Part 190
Pipeline Safety: Adjustment to OPID Notifications for Construction PHMSA proposed adjusting the inflation-based threshold that triggers OPID notifications for certain construction and facility modification activities. NPRM 49 CFR Part 191
Pipeline Safety: Eliminating Limitations on Welders and Welding Operators PHMSA proposed allowing welders qualified through non-destructive testing methods to perform compressor station welding activities currently subject to additional restrictions. NPRM 49 CFR Part 192
Pipeline Safety: Material Properties Verification During MAOP Reconfirmation PHMSA proposed clarifying that material testing at pressure test manifold sites is not required when traceable, verifiable, and complete material records already exist. NPRM 49 CFR Part 192
Pipeline Safety: Electronic Retention of Part 194 Response Plans PHMSA amended regulations to allow operators to maintain electronic copies of response plans instead of paper copies. DFR 49 CFR Part 194
Pipeline Safety: Remote Monitoring of Rectifiers PHMSA proposed allowing remote monitoring technologies for rectifiers used in external corrosion control programs. NPRM 49 CFR Part 195
Pipeline Safety: Clarifying Hazardous Liquid High-Consequence Area Designations PHMSA amended HCA guidance to clarify spill considerations in agricultural fields and reorganize threat identification guidance. DFR 49 CFR Part 195
Pipeline Safety: Timeframe to Make Rupture-Mitigation Valves Operational PHMSA proposed extending the deadline for placing rupture-mitigation valves into operation from 14 days to 90 days after a pipeline enters service. NPRM 49 CFR Part 192
Pipeline Safety: Hazardous Liquid Valve Maintenance Schedule PHMSA proposed allowing operators to implement risk-based valve maintenance schedules, subject to a maximum inspection interval of one year. NPRM 49 CFR Part 195
Pipeline Safety: Property Damage Definition for Incident Reporting PHMSA proposes revising property damage thresholds for reportable gas and hazardous liquid pipeline incidents and clarifying applicability to telephonic notifications. NPRM 49 CFR Parts 192 & 195
Pipeline Safety: Remote Sensing Technologies for ROW Patrols PHMSA proposes clarifying that unmanned aerial systems, satellites, and other remote-sensing technologies may be used to satisfy right-of-way patrol requirements. NPRM 49 CFR Parts 192 & 195
Pipeline Safety: Adjust Annual Report and NPMS Filing Timelines PHMSA proposes extending annual report and NPMS submission deadlines for gas pipeline and storage operators to June 15 each year. NPRM 49 CFR Part 191
Pipeline Safety: Editorial Corrections and Clarifications PHMSA issued multiple final rules correcting editorial errors, updating references, removing obsolete submission methods, and improving regulatory clarity. Final Rules Various
Pipeline Safety: Update of Standards Incorporated by Reference PHMSA issued multiple direct final rules updating incorporated industry consensus standards, including NFPA, ASTM, MSS, NACE, and ASME standards. Multiple DFRs 49 CFR Parts 192 & 195

Have questions about an upcoming deadline? Please reach out to Jessica Foley for assistance!

Last Updated: October 2026

PSI Training Schedule

[rcp_psi_training]

WEBINAR RECORDING!
Unpacking the Key Updates in API RP 1170 & 1171, 2nd Edition

RCP and the Pipeline Safety Institute offered a free webinar exploring the 2nd Editions of API RP 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage and API RP 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs. Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!

WEBINAR RECORDING
Pipeline Safety: Unpacking the Class Location Change Requirements

Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!

You asked and we listened!

Advanced DOT Pipeline Compliance Workshop is on the calendar!

This intensive and interactive 3-day, in-person workshop is designed for those who have previously completed our DOT Pipeline Compliance Workshop and are ready to take their knowledge to the next level.

New Workshop Alert!

Prepare Your Team for Pipeline Safety Audits with Confidence!

Our 3-day Pipeline Safety Audit Workshop is tailored for professionals responsible for the safe operation of hazardous liquid and natural gas pipelines. Designed for groups of 10-15 participants, this interactive training…

On-Site Training Request

We have conducted on-site training for oil and gas companies for over 25 years and can provide customized workshops for companies with groups of five or more.

We would welcome the opportunity to discuss our services with you.

Sincerely,

W. R. (Bill) Byrd, PE
President
RCP Inc.