The Pipeline and Hazardous Materials Safety Administration (PHMSA) has announced that the new construction inspection provision of 192.305 that was to become effective on October 1st has been delayed indefinitely. The rule has caused great concern in that it would require operators to hire outside contractors to inspect new mains and transmission lines constructed by utility crews. Further details are expected when the Federal Register announcement is published. A working group formed by PHMSA to help fix the rule, including representatives from American Public Gas Association (APGA), will be meeting and the hope is that when the work is completed PHMSA will hold a public meeting to explain how it expects operators to comply.
John Erickson, VP of Operations at APGA, is on the working group representing municipals. One of their first tasks is to understand exactly what inspections are covered by the rule. IAMU has submitted several questions to Erickson along with others from around the country. The working group will use this list of questions as a starting point to drill down to what inspections are covered by 49 CFR Part 192.305.
Another issue to be discussed by the working group is whether the rule should be limited to only inspections required by Subpart G, i.e. only those numbered 192.3XX in the attachment, or all of Part 192. The March 11, 2015 final rule only applied to Subpart G, but PHMSA says that was a typo and it intended it to apply to all inspections in Part 192. APGA expects the announcement of the postponement of the effective date will include a “technical correction” changing “subpart” to “part.” The industry members of the working group agreed that as long as the construction inspection requirements are reasonable, applying it to all inspections could be agreed to. Since inspections are required by other sections of Part 192, the only impact of the changes to section 305 is not whether these inspections must be performed, but rather who can perform them. APGA’s and IAMU's #1 priority is ensuring that utility employees can continue to perform all of these inspections.
Another issue to be discussed by the working group is whether the rule should be limited to only inspections required by Subpart G, i.e. only those numbered 192.3XX in the attachment, or all of Part 192. The March 11, 2015 final rule only applied to Subpart G, but PHMSA says that was a typo and it intended it to apply to all inspections in Part 192. APGA expects the announcement of the postponement of the effective date will include a “technical correction” changing “subpart” to “part.” The industry members of the working group agreed that as long as the construction inspection requirements are reasonable, applying it to all inspections could be agreed to. Since inspections are required by other sections of Part 192, the only impact of the changes to section 305 is not whether these inspections must be performed, but rather who can perform them. APGA’s and IAMU's #1 priority is ensuring that utility employees can continue to perform all of these inspections.
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