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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-77-0101

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:

Country: US

View the Interpretation Document

Response text:

Mr. Latta W. Cook
Pipeline Safety Coordinator
LP Gas Bureau
Office of State Fire Marshal
1114 E. Kennedy Boulevard
Tampa, Florida 33602

Dear Mr. Cook:
Your letter of December 6, 1976, suggests that in referencing NFPA standard No. 58 under 49 CFR
192.11, the “current issue” be referenced, and that the referenced standard be applied to a
petroleum gas system “up to the first stage regulator.” You indicate that the suggested changes
would give regulatory authorities guidance regarding which standard to apply up to the first stage

Amendment 192-22 to 49 CFR part 192, published in the Federal Register on march 31, 1976 (41 FR
13590), incorporated by reference the 1972 edition of NFPA standard no. 58 under 49 CFR 192.11 and
appendix A to part 192. Later editions of the document will be reviews and, if found acceptable,
also proposed for incorporation by reference. We cannot, however, adopt you suggestion that the
“current issue” be authorized for use since as a matter of law only a particular edition of a
referenced standard can qualify as a Federal regulation.  We do recognize the problems created when
existing documents incorporated by reference become outdated and, as a consequence, endeavor to
keep the references current.

In accordance with the definition of “service line” under 49 CFR 192.3, the Federal safety
standa5rds, including those under 192.11 applicable to petroleum gas systems, apply to pipelines up
to a customer meter or the connection to a customer’s piping, whichever is farther downstream. We
believe that this jurisdictional limit is sufficient for all systems and that it would be confusing
to establish a different jurisdictional limit, such as “up to the first stage regulator,” in the
case of petroleum gas systems.
Sincerely, Cesar DeLeon Acting Director Office of Pipelines Safety Operations
December 6, 1976
Mr. Cesar DeLeon
Acting Director
Office of Pipeline Safety Operations Materials
Transportation Bureau Washington, D.C. 20590
Re: OPSO Advisory Bulletin No. 76-10 - October 1976 Interpretation of Regulation

Dear Mr. DeLeon:
As we previously noted in a letter to Webster B. Todd, Jr., the State of Florida Liquefied
Petroleum Gas Bureau considers the petroleum gas tanks connected to distribution systems (10 or
more customers) are subject to the National Fire Protection Association Pamphlet 58 standards
referenced in 192.11. Since this reference standard is in
192.11 then this becomes the standard applicable to the installation of the tanks and

This Standard is revised periodically and the referenced issue is 1969. Since the revisions are
generally more stringent and afford more protection for the public, we suggest the referenced
standard National Fire Protection Association Pamphlet 58 be the current issue of that standard.

We suggest to you a clarification to your interpretation would be: that portion of a petroleum gas
distribution system up to the first stage regulator is subject to standards set forth in National
Fire Protection Association Pamphlet 58 current issue.

This would then give regulatory authorities guidance of which standard to apply to that portion of
the system up to the first stage regulator.

Sincerely yours, Latta W. Cook
Pipeline Safety Coordinator

Regulation Sections

Section Subject
192.3 Definitions