No. A retail Duty to Warn mailing and the pipeline duty in 49 CFR 192.616 are separate jobs. If paragraph (j) applies, you need a written procedure and messages twice a year. A retail brochure alone does not prove that you met the pipeline rule.
By Bill Stomp · Last updated:
Primary sources: 49 CFR 192.616 · 49 CFR 192.1 · 49 CFR 172.704.
Where does the pipeline duty start?
First check 49 CFR 192.1. The rule covers some gas systems and leaves others out. Your pipeline regulator can review the system map and customer count.
Under 49 CFR 192.616, qualifying master-meter and petroleum-gas operators use paragraph (j). Its exception depends on whether gas transport is the primary activity. Other covered operators need the full public education program.
How should the office track each job?
We suggest two clear entries in the work list. For the retail mailing, track the piece, list and mailing record. For the pipeline duty, track the system, rule, procedure, message and audience.
The same brochure may help with both jobs. First check what it says and who gets it. Paragraph (j) calls for five topics and two messages a year. A vendor invoice cannot show that all of those steps took place.
Questions owners ask
Can we use the same brochure?
Possibly. Check all five topics and the full audience first. One mailing does not prove that two yearly messages went out.
Is employee training the same notice?
No. 49 CFR 172.704 covers hazmat staff training and records. Pipeline public awareness reaches a different audience. Keep each job clear.
Where should the manager start?
Get the system’s coverage checked. Then identify the part of 192.616 that applies. Use that answer to review the existing mailing.
General information, not legal advice. Check your system’s rules with your pipeline regulator and your own lawyer.
Before your next mailing, bring us the piece and the list you plan to use.