Interpretation Response #PI-76-028 ([Detectable Subsurface Tape Institute] [Paul A. Potter])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 05/27/1976

Company Name: Detectable Subsurface Tape Institute

Individual Name: Paul A. Potter

Location State: IL Country: US

View the Interpretation Document

Response text:

May 27, 1976

Mr. Paul A. Potter
Detectable Subsurface Tape Institute
P.O. Box 12
Deerfield, Illinois 60015

Dear Mr. Potter:

Your letter of April 22, 1976, petitioning to amend 49 CFR 192.321(e) to include a definition of
the term "other means" is assigned Docket No. 76-6.

Section 192.321(e) requires that unencased plastic pipe have an electrically conductive wire or "other means" of locating the pipe underground, and you suggest that the "other means" include a detectable tracer tape which can be located from the surface by a pipe/cable locator.

Section 192.321(e) is written in performance type language rather than specification terms. In
general, performance regulations state an objective requirement but leave the specific means of
compliance to the selection of the operator. Thus, with regard to locating plastic pipe, there may
conceivably be many means other than detectable tracer tape, and it would be impractical to
include detailed specifications for each means within Section 192.321(e). Therefore, it would not
be appropriate to amend §192.321(e) as you have suggested to make specific provision for
detectable tracer tape even though it appears to meet the present standard. Accordingly, the
petition is denied.

We appreciate your interest in this matter.

Sincerely,

'signed'

Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections