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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-12-0008 ([Associated Safety Consultants, Inc.] [Mr. Michael J. Frenzel])

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

Interpretation Response Details

Response Publish Date:

Company Name: Associated Safety Consultants, Inc.

Individual Name: Mr. Michael J. Frenzel

Location State: LA Country: US

View the Interpretation Document

Response text:

Mr. Michael J. Frenzel
Associated Safety Consultants, Inc.
8315 Kelwood Avenue
Suite B
Baton Rouge, LA  70806

Dear Mr. Frenzel:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated August 9, 2012, the Associated Safety Consultants (ASC), Inc., requested an interpretation of the applicability of the Federal pipeline safety regulations at 49 CFR 192.317(b) to an aboveground gas transmission line or main.  Specifically, ASC asks PHMSA's interpretation of how a 'safe distance' is defined or determined, and what would constitute an effective barricade?

Section 192.317(b) reads as follows:

(b) Each aboveground transmission line or main, not located offshore or in inland navigable water areas, must be protected from accidental damage by vehicular traffic or other similar causes, either by being placed at a safe distance from the traffic or by installing barricades. 

PHMSA has not adopted general criteria to judge the safety of distances and effective barricades separating aboveground gas pipeline facilities from vehicular traffic.  Therefore, a safe distance and effective barricade would be whatever a reasonable and prudent pipeline operator would conclude is safe under the site specific circumstances, considering relevant factors such as the speed limit, the direction of traffic, the terrain, and any natural barriers.

I hope that this information is helpful to you.  If I can be of further assistance, please contact me at 202-366-4046.



John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.317 Protection from hazards