Do We Have to Notify Customers About Buried Piping We Do Not Maintain?

Yes, if 49 CFR 192.16 applies and you do not maintain the defined buried piping. Give one written notice. For new service today, send it within 90 days after gas service starts. A master-meter operator may instead keep a general notice posted where customers go.

By Bill Stomp · Last updated:

Primary sources: 49 CFR 192.16.

Which piping does this mean?

First confirm Part 192 coverage under 49 CFR 192.1. Then check the pipe boundary in 49 CFR 192.16. It runs up to the entry of the first building downstream. If the buried pipe does not enter a building, it runs up to the main gas-use equipment, or the first fence or wall around that equipment. Branches to yard lights, pool heaters and other secondary equipment are left out.

The rule defines maintenance too. It includes corrosion checks for metal pipe, leak surveys and action on an unsafe condition. Ask your regulator to check who does that work. Tank ownership alone does not answer it.

What must the notice say?

Say that the operator does not maintain the piping. Say that if the piping is not maintained, it may corrode and leak. Tell customers it needs periodic leak checks, corrosion checks if metal, and repair when unsafe. Before digging near it, the pipe should be found and digging done by hand.

Name the operator, if applicable, and plumbing and heating contractors as sources of help with finding, checking and fixing the pipe. Keep the current notice and proof of notices sent in the past three years ready for inspection.

Questions owners ask

Is this an annual notice?

No. Give one written notice, unless a master-meter operator keeps a general notice posted where customers go. The deadline is the later of August 14, 1996, or 90 days after first getting gas at that site.

Can a master-meter operator post the notice?

Yes. Section 192.16(c) permits a general notice kept on display in a prominent place customers use. This option is for master-meter operators.

Does every tank customer fall under this rule?

No. Check Part 192 scope, the service-line operator and who maintains the defined piping. Have the regulator confirm those facts.

General information, not legal advice. Check your system’s rules with your pipeline regulator and your own lawyer.

Use the rule’s checklist to review your notice. Then ask us how to keep the notice and sending record together.