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Interpretation Response #PI-71-0120 ([ACF Industries] [Mr. R. D Wilkins])

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

Interpretation Response Details

Response Publish Date:

Company Name: ACF Industries

Individual Name: Mr. R. D Wilkins

Location State: TX Country: US

View the Interpretation Document

Response text:


December 15, 1971

Mr. R. D Wilkins, Manager
Applications Engineering
Engineering and Research
ACF Industries
P.O. Box 2117
Houston, Texas 77001

Dear Mr. Wilkins:

Thank you for your letter of November 22, 1971, that inquired about the interpretation of 49 CFR §§192.505 (c) and (d).

You are correct in your understanding that in the very limited circumstances delineated in §192.505 (d) the requirements for a strength test and for maintaining test pressure for eight hours is not required. Thus, if a component other than pipe is the only item being replaced or added to a pipeline, a strength test after installation is not required, if the manufacturer of the component certifies that (1) the component was tested to at least the pressure required for the pipeline to which the component is being added, or (2) the component was manufactured under a quality control system that ensures that each item manufactured is at least equal in strength to a prototype and that the prototype was tested to at least the pressure required for the pipeline to which it is being added.

The reason for this exception is that if the manufacturer meets either of the requirements of §192.505 (d) an equivalent level of safety to §192.505 (c) is maintained without the burden of the eight hour test.

We trust that this will satisfactorily clarify the regulations for you.


Original signed by:
Joseph C. Caldwell
Acting Director
Office of Pipeline Safety

Regulation Sections

Section Subject
192.505 Strength test requirements for steel pipeline to operate at a hoop stress of 30 percent or more of SMYS