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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-18-0018

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

Interpretation Response Details

Response Publish Date:

Company Name: Praxair

Individual Name: Mr. John P. Maitino

Location State: TX Country: US

View the Interpretation Document

Response text:

Mr. John P. Maitino
Regulatory Compliance Manager
200 Strang Road
LaPorte, TX 77571

Dear Mr. Maitino:

In an August 10, 2018, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 Code of Federal Regulations (CFR) Part 192. Specifically, you requested interpretation for welding requirements under § 192.225.

You stated Praxair currently utilizes a Praxair-owned Welding Standard (W-40) that requires the contract welder to meet certain requirements before they are qualified to weld on a Praxair Hydrogen pipeline. You listed electrode and rod types and standards, stated the welding procedure, and stated how welders would be qualified.

You seek an interpretation whether § 192.225 requires Praxair to have its own written welding procedures or whether it is adequate to ensure that the qualified welder has compliant welding procedures if the welder meets the standards you listed in your request.

Section 192.225 is specific in its requirements. The section states:

§ 192.225 Welding procedures.
(a) Welding must be performed by a qualified welder or welding operator in accordance with welding procedures qualified under section 5, section 12, Appendix A or Appendix B of API Std 1104 (incorporated by reference, see § 192.7), or section IX of the ASME Boiler and Pressure Vessel Code (ASME BPVC) (incorporated by reference, see § 192.7) to produce welds meeting the requirements of this subpart. The quality of the test welds used to qualify welding procedures must be determined by destructive testing in accordance with the applicable welding standard(s).
(b) Each welding procedure must be recorded in detail, including the results of the qualifying tests. This record must be retained and followed whenever the procedure is used.

The pipeline operator is required by § 192.225(a) to require welding using welding procedures qualified under one of the specified standards for a qualified welder or welding operator. Also, § 192.225(b) requires the pipeline operator to retain welding records and written welding procedures. Therefore, at a minimum, it is Praxair's responsibility, as pipeline operator, to keep welding written procedures and records.

If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.


John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.225 Welding procedures