Yes, for a master-meter system under 49 CFR 192.625(f). You need both written gas-source proof of proper odorant levels and periodic sniff tests at the system’s far ends. A source letter alone is not enough. Check Part 192 coverage and the applicable NFPA rules before using this option.
By Bill Stomp · Last updated:
Primary sources: 49 CFR 192.625 · 49 CFR 192.11.
What are the two parts?
49 CFR 192.625 normally calls for periodic sampling with an instrument. It must measure the gas-in-air level at which the smell is easy to detect. The master-meter option uses written source proof plus periodic sniff tests at the system’s extremities, or far ends.
We suggest keeping both records easy to find. Include the dates and actual test sites. A field smell check alone leaves out the source proof.
What should we check first?
Confirm scope under 49 CFR 192.1 and the system type with your pipeline regulator. Under 49 CFR 192.11, covered petroleum-gas systems also follow the applicable NFPA 58 or NFPA 59 standard. That standard takes priority if it conflicts with Part 192.
Have qualified staff confirm the method and test schedule. This page gives no hands-on test steps or fixed interval. Do not ask an untrained person to release gas.
Questions owners ask
Does every propane retailer qualify for this alternative?
No. Paragraph (f) gives this option to master-meter operators. Buying gas that already has odorant does not prove that your system qualifies.
Is written supplier verification enough by itself?
No. You also need periodic sniff tests at the system’s far ends. Keep proof of the actual checks with the source letter.
Does a sniff-test record replace the customer safety notice?
No. A test records an operator’s task. The public message under 192.616 is a separate job. Keep evidence for each duty that applies.
General information, not legal advice. Check your system’s rules with your pipeline regulator and your own lawyer.
Once your regulator confirms the method, ask us to show how you can organize its records.