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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-76-0111

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name:

Location State: OK Country: US

View the Interpretation Document

Response text:

August 31, 1976

Mr. A. R. Kahmann
Chief Engineer
Chandler Engineering Company
7707 East 38th Street
Tulsa, OK  74145

Dear Mr. Kahmann:
This responds to your letter dated July 23, 1976, asking whether accessory test equipment is
subject to 49 CFR Parts 192 and 195.

There are no specific regulations governing accessory test equipment in 49 CFR Parts 192 and
195.  However, if accessory test equipment is installed in a pipeline (including pipe, valves, and
other appurtenance attached to pipe, compressor units, pump stations, metering stations, regulator
stations, delivery stations, holders, and fabricated assemblies) as a physical facility through
which gas or liquid move in transportation, then it is subject to the general requirements
governing design, construction, operation, and maintenance of a pipeline.  We suggest that you
contact the operators who purchased the accessory test equipment you manufacture to determine
whether or not the equipment is used as part of a pipeline.

Thank you for your interest in pipeline safety.
Sincerely, Cesar DeLeon Acting Director Office of Pipeline Safety Operations

TO:   Mat'l Trans Bureau    ATTN: Cesar DeLeon
Office of Pipeline Safety Operations
2100 Second St, S.W. Washington, D.C.  20590

SUBJECT:     Our letter of 23 July

11 Aug 76



We would appreciate your review and answer to our letter, copy enclosed. Thank you.
23 July, 1976
Material Transportation Bureau
Office of Pipeline Safety Operations
2100 Second Street, S.W. Washington, D.C.  20590

Attention:  Cesar De Leon, Director

We are manufactures of Dead-Weight Pressure Measuring Instruments.  These instruments are used both
in the construction and operation of gas and product pipelines, for exact pressure determinations.

We have received orders from some of our customers requesting that instruments we furnish
them "meet all of the applicable provisions of the Department of Transportation Minimum Safety

We have reviewed Federal Regulations Title No. 49, Section 192 and find no specific reference to
accessory test equipment.  We would appreciate assistance from your office directing us to the
specific Sections of the Law that would apply to our equipment.  Any pertinent excerpts you might
forward to us would be appreciated.
Thank you.

Very truly yours,
Chief Engineer

Regulation Sections

Section Subject
192.517 Records