No. For a covered pipeline, 49 CFR 192.625 deals with gas odor and sampling. Section 192.616 deals with public messages. Sending a warning does not perform a test. Before choosing either procedure, confirm Part 192 coverage and the NFPA rules that apply to your system.
By Bill Stomp · Last updated:
Primary sources: 49 CFR 192.625 · 49 CFR 192.11.
What does the odor rule require?
Check scope under 49 CFR 192.1 first. 49 CFR 192.625 paragraph (a) sets a smell threshold for gas in a distribution line. A person with a normal sense of smell must readily detect it at one-fifth of its lower explosive limit in air.
Paragraph (f) calls for periodic sampling with an instrument that measures the gas-in-air level at which the smell is easy to detect. This is work for qualified staff. Do not ask customers to make a gas mixture or hunt for leaks by smell.
Where should we keep the evidence?
49 CFR 192.11 calls for the applicable NFPA 58 or NFPA 59 standard too. That standard takes priority in a conflict with Part 192. Have your regulator confirm the rules before setting a test method.
We suggest separate files for tests and warnings. Record what staff actually checked. A supplier letter is not your instrument result. Under section 192.616(j), leak signs and response belong in the public message. That message is not a sampling test.
Questions owners ask
Does mailing a gas-smell warning satisfy sampling?
No. Mailing and sampling are separate tasks. Keep proof of each one that applies. Confirm the test rule with qualified staff and your regulator.
Can every operator use sniff tests instead of an instrument?
No. Paragraph (f) gives master-meter operators a two-part option: written gas-source proof and periodic sniff tests at the system’s far ends.
Does this page set a sampling interval or retention period?
No. The section calls for periodic sampling. Ask your regulator and qualified staff to confirm the schedule and record rules for your system.
General information, not legal advice. Check your system’s rules with your pipeline regulator and your own lawyer.
Bring a sample test record and warning file to a Safety App record review.