Interpretation Response #PI-77-0107

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

Interpretation Response Details

Response Publish Date: 10/17/1977

Company Name:

Individual Name:

Location State: DC Country: US

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Response text:

October 17, 1977

Honorable Andy Ireland
1513 Longworth House
Office Building
House of Representatives
Washington, D.C.  20515

Dear Congressman Ireland:
In response to your letter of September 12, 1977, we are stating the views of the Materials
Transportation Bureau on Mr. Jesse R. Lowe's comments about the Federal gas pipeline safety
regulations.

Mr. Lowe questions the benefit of the regulations in light of statistics released by the National
Transportation Safety Board, showing that in 1976 only 82 persons died in pipeline accidents while
over
44,000 persons were killed in highway accidents.  Although it is true that deaths from pipelines
are relatively small when compared to other modes of transportation, gas pipelines present a
potential for catastrophe that the public will not tolerate without proper Government regulation of
safety.  If left unattended, the many thousands of gas leaks which annually occur nationwide could
lead to major disasters.  For example, 20 of the 82 deaths in 1976 resulted from a single incident
at a hotel in Fremont, Nebraska.  Gas leaking from a 2-inch plastic pipeline seeped into the hotel
beneath frozen earth and concrete where it exploded, destroying the hotel and damaging nearby
buildings.  Based in part on an investigation of this incident, the Office of Pipeline Safety
Operations is developing new safety
standards for the installation of plastic pipe.

We do not believe that Mr. Lowe's assessment of his company's cost of compliance with the safety
standards should be taken as an example of the impact the standards have had on the gas industry.  
For the most part, the standards have been based on actual safety practices followed by prudent gas
operators or on self-imposed industrial standards.  Viewed in this respect, we believe the true
cost of compliance
to the industry has not been much above the cost that would have been met in the absence of the
Federal standards.

I would like to suggest that you advise Mr. Lowe that our procedures under 49 CFR Part 102 (copy
enclosed) permit interested persons line him to request changes in the safety standards that are
considered too burdensome or expensive in comparison with the benefits to be achieved.  Mr. Lowe is
also free to request a waiver from compliance with any standard which appears to be inappropriate
when applied to a particular situation.
Sincerely,
John J. Fearnsides
Acting Director

Regulation Sections