Operations & Maintenance Enforcement Guidance Part 192 Subparts L and M

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Enforcement Guidance

O&M Part 192

Revision Date


Code Section


Section Title

Procedural Manual – General Provisions

Existing Code Language

(a) No person may operate a segment of pipeline unless it is operated in accordance with this subpart.

(b) Each operator shall keep records necessary to administer the procedures established under §192.605.

(c) The Administrator or the State Agency that has submitted a current certification under the pipeline safety laws, (49 U.S.C. 60101 et seq.) with respect to the pipeline facility governed by an operator's plans and procedures may, after notice and opportunity for hearing as provided in 49 CFR 190.237 or the relevant State procedures, require the operator to amend its plans and procedures as necessary to provide a reasonable level of safety.

Origin of Code

Original Code Document, 35 FR 13257, 08-19-1970

Last Amendment

Amdt. 192-75, 61 FR 18517, 04-26-1996

Interpretation Summaries

Interpretation: PI-93-047 Date: 08-05-1993
Under parts 191 and 192, operators may use any recordkeeping procedure that produces authentic records, without the prior approval of this agency. Although authenticity of records concerns us – for both computer and paper records - we do not believe there is sufficient need to adopt generally applicable standards governing recordkeeping procedures.
Interpretation: PI-11-046 Date: 07-15-1993
The regulations governing the transportation of gas by pipeline are in 49 CFR Part 192. These regulations do not contain inspection requirements that apply specifically to customer meter sets. However, because customer meter sets are part of service lines, the sets are subject to the same inspection requirements as service lines. These requirements include monitoring for atmospheric corrosion under §192.481 and periodic leakage surveys under §192.723.
Records of corrosion inspections are required by §192.491, and §192.603(b) requires records of leakage surveys. These records may cover pipelines as a whole, and need not identify specific parts of the pipeline, such as customer meter sets.

Interpretation: PI-11-030 Date: 01-26-1983
There is no current design requirement for scraper traps in the Part 192 equal to §195.124, nor is there a requirement in Part 192 comparable to §195.426. However, the operating requirements of §§192.603(b) and 192.605(a) may be applied to scraper traps.
Interpretation: PI-11-15 Date: 11-06-1974
It is not mandatory that an operator include material presented by PHMSA at industry seminars in an operating and maintenance plan under Section 192.603(b). The material is presented as a guide to operators. A single operator and maintenance plan may suffice for running all of the systems. However, any peculiarities in a system must be covered as required by Part 192 in the operator's plan, either in the single plan or in a separate plan.
Interpretation: PI-72-031 Date: 07-17-1972
Section 192.603(b) requires that each operator shall establish a written operating and maintenance plan meeting the requirements of the Federal gas safety regulations and keep records necessary to administer the plan. If an operator requires maps as a record to properly administer the operating and maintenance plan to meet the Federal safety requirements, then these maps must be maintained by the operators.

Advisory Bulletin/Alert Notice Summaries

Other Reference Material

& Source

GPTC Guide Material is available.

See also GPTC Guide Material under §192.605

Guidance Information

  1. Paragraph §192.603(a) is a general compliance requirement that is used in conjunction with another specific violation within this subpart.

  2. If possible, a more specific regulation within Part 192 and/or provisions within the operator’s operations and maintenance procedures should be used as the primary citation with §192.603 providing additional support.

  3. When a regulation does not specifically require records, then paragraph §192.603(b) can be used when appropriate records have not been kept.

Examples of a



  1. Operating a segment of the pipeline system that is not in accordance with this subpart.

  2. Records necessary to administer the procedures required by §192.605 are not maintained.

  3. Computerized records were not managed properly, did not have adequate information to verify the inspection, records were lost, deleted or otherwise destroyed.

  4. Records lack sufficient details to document the actual work performed.

Examples of Evidence

  1. If missing record(s) are an issue, copies of the associated records for adjacent intervals either side of the missing record should be acquired.

  2. If paper or electronic records are incomplete, copies or printouts of the incomplete records should be acquired.

  3. A copy of the operator’s operations and maintenance procedures associated with the required record should be acquired.

  4. Document from whom, when, and where the records were requested, and that the operator was unable to provide the requested records or that the inspections were not properly recorded to be included in inspection and the violation summary.

  5. The inspector may want to issue a Request for Specific Information (RFSI) to further document the records request and the missing records if the operator fails to provide an appropriate response.

Other Special Notations

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