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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-76-013 ([Brown & Root, Inc.] [Hines D. Lively])

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

Interpretation Response Details

Response Publish Date:

Company Name: Brown & Root, Inc.

Individual Name: Hines D. Lively

Location State: TX Country: US

View the Interpretation Document

Response text:

March 26, 1976

Mr. Hines D. Lively
Manager, Piping Design
Brown & Root, Inc.
P.O. Box 3
Houston, TX 77001

Dear Mr. Lively:

This is in response to your letter of January 21, 1976,
requesting information concerning the jurisdiction of the Federal
standards for the Transportation of Liquids by Pipeline, Part 195
of Title 49 of the Code of Federal Regulations (Part 195), and
the ANSI B31.4, Code for Pressure Piping, Liquid Petroleum
Transportation Piping Systems.

Under the Transportation of Explosives Act, 18 U.S.C. 831-835,
the Department of Transportation (DOT) has jurisdiction over
common, contract, and private carriers engaged in interstate or
foreign commerce who transport liquid hazardous materials by
pipeline. Safety regulations issued under 18 U.S.C. 834
governing the design, construction, operation, and maintenance of
interstate liquid pipelines are published in Part 195.

The ANSI B31.4 code is an industry standard developed under the
direction of the American National Standards Committee B31
organized under the procedures of the American National Standards
Institute, Inc., and is under the administrative sponsorship of
the American Society of Mechanical Engineers. ANSI B31.4 is
enforceable as a Federal standard only for the specific
paragraphs referenced in Part 195.

The following is our response to your specific questions:

Question 1: Does a pipeline as shown in SK-1-20-76 fall under
the jurisdiction of DOT or only ANSI B31.4? Please answer
separately for sections A, B, and C as shown on sketch.

Sections A, B, and C would be subject to the regulations in 49
CFR Part 195 only if they are used in the transportation of
liquid hazardous materials by pipeline in interstate or foreign

The electrical transmission line indicated in the lower part of
Sketch SK-1-20-76 is not a part of the pipeline and is not
considered when the question of pipeline jurisdiction is

Question 2: When DOT does apply does section 421 apply (which is
not even referred to by Title 49) or does section 195.208 apply?

Section 421, Design of Pipe Supporting Elements, in ANSI B31.4
has not been referenced in Part 195 and is not applicable;
however, Section 195.208, Welding of supports and braces, in Part
195 is applicable.

Question 3: If 195.208 applies, is nonintegral support

The regulations in Part 195 are for the most part performance
standards. Where a specific method is neither required nor
excluded then the operator has the responsibility of selecting a
method of compliance that will conform with the appropriate

Questions 4: If not, can "excess thickness" be considered
sufficient reinforcement is lieu of a "cylindrical member
continuously welded around the pipe."

This question is moot as the answers to questions 2 and 3
indicate that Section 195.208 is applicable.

ANSI B31.4 is not a Federal standard unless it is specifically
referenced in Part 195. The Office of Pipeline Safety Operation
considers it a useful guide, providing procedures that may be
helpful in complying with the performance requirements of the
Federal standards. Any questions you might have relative to ANSI
B31.4 should be directed to:

American National Standards Committee B31
The American Society of Mechanical Engineers

United Engineering Center

345 East 47th Street

New York, New York 10017

We appreciate your interest in pipeline safety. If you have any
further questions, do not hesitate to call or write.


Cesar DeLeon

Acting Director

Office of Pipeline

Safety Operations

Regulation Sections

Section Subject
195.1 Which pipelines are covered by this Part?
195.208 Welding of supports and braces