Interpretation Response #PI-76-028
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
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
| Section | Subject |
|---|---|
| § 192.321 | Installation of plastic pipe |