Part 192 applies to gas pipeline systems, with some exceptions. Owning a bobtail does not settle the question. Section 192.1(b)(5) looks at the gas, the number of customers and where the pipe runs. Map your system. Then ask your pipeline regulator which rules apply.
By Bill Stomp · Last updated:
Primary sources: 49 CFR 192.1 · 49 CFR 192.11.
Which systems are left out?
49 CFR 192.1 lists two options for systems that carry only petroleum gas or petroleum gas/air mixtures. One serves fewer than 10 customers and has no part in a public place. The other serves one customer, with all of the system on that customer’s premises. The second option can include a public place.
Check each option on its own. “Fewer than 10” does not mean “10 or fewer.” A count alone is not enough.
What should I bring to the review?
Bring a pipe map. Mark the supply, customer land and public places. List who runs each part and how many customers it serves. We suggest keeping the map with the regulator’s written answer.
49 CFR 192.11 also calls for NFPA 58 or NFPA 59 where that standard applies. In a conflict with Part 192, the applicable NFPA standard wins. Ask which code text and state rules govern your system.
Questions owners ask
Does owning a bobtail decide pipeline jurisdiction?
No. The rule looks at the pipeline and gas transport. Have the regulator review the actual system.
Are fewer than 10 customers always excluded?
No. That option also limits the gas carried and rules out any part in a public place. Check the separate one-customer option too.
Does exclusion from Part 192 remove all safety duties?
No. State gas rules, adopted codes and workplace rules may still apply. Ask which duties remain.
General information, not legal advice. Check your system’s rules with your pipeline regulator and your own lawyer.
First, get the system’s status clear. Then ask us to review how you keep the notice records.