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Interpretation Response #PI-71-004 ([Compressed Gas Association, Inc.] [Robert E. Lenhard])

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

Interpretation Response Details

Response Publish Date:

Company Name: Compressed Gas Association, Inc.

Individual Name: Robert E. Lenhard

Location State: NY Country: US

View the Interpretation Document

Response text:

January 4, 1971

Mr. Robert E. Lenhard

Managing Director

Compressed Gas Association, Inc.

500 Fifth Avenue

New York, New York 10036

Dear Mr. Lenhard:

This is in reply to your letter of December 1, 1970, addressed to Mr. William K. Byrd, which was
referred to this office for reply. You questioned the advisability of applying the requirements of
49 CFR, Section 192.625 to hydrogen to be used for food processing, and other applications of
odorization where the odorant could have a detrimental effect on the end use of gas.

Your earlier comments were carefully considered in the rulemaking process. No reply was sent
you, since it is our practice not to reply to comments on our proposed rulemaking. All such
comments are part of a docket and available for public inspection. Comments on odorization
were also considered at and after an informal public hearing held on September 17, 1970.

From your letter it appears that some of your facilities may not be included in the jurisdiction of
this Office under the Natural Gas Pipeline Safety Act of 1968. That is to say, they appear not to
be engaged in the transportation of gas by pipeline. However, should your members interpret
themselves to be within this jurisdiction, they may wish to apply for a waiver of the regulations as
provided for in Section 3(e) of the Natural Gas Pipeline Safety Act of 1968 (49 USC 1671 et

Thank you for your interest in the pipeline safety program.


Joseph C. Caldwell

Director, Acting

Office of Pipeline Safety

Regulation Sections

Section Subject
192.625 Odorization of gas