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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-78-017 ([various] [various])

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

Interpretation Response Details

Response Publish Date:

Company Name: various

Individual Name: various

Location State: TX Country: US

View the Interpretation Document

Response text:

Mr. Robert Steffan, Chairman

Southern California Cathodic

Protection Committee

National Association of Corrosion Engineers

Mr. M.J. Schiff, Director

Los Angeles Section

National Association of Corrosion Engineers

P.O. Box 1499

Houston, Texas 77001


This responds to your letter of April 19, 1978, regarding your assertion that some of the corrosion contractors are not qualified and are doing substandard corrosion work for master
meter system operators trying to comply with the Federal pipeline safety standards.

You ask what enforcement is available from Federal and State agencies. You further inquire if it is practical to require persons designing and/or installing corrosion control systems to accept some legal responsibility for their work.

The Federal standard (192.453) require the operator to "...establish procedures to implement the requirements of this subpart" and that "...the design, installation, and maintenance of cathodic protection systems must be carried out, by or under the direction of a person qualified by experience and training in pipeline corrosion control methods." This Office has jurisdictional authority over operators of natural gas pipeline systems under the Natural Gas Pipeline Safety Act of 1968 and, therefore, our surveillance and enforcement program is directed toward operators to assure that they comply with the Federal gas pipeline safety standards. Since our authority does not extend to corrosion contractors designing and installing cathodic protection for such operators, we cannot place requirements on such contractors. This is not to say that operators and corrosion contractors cannot enter into contractual relationships that place a legal responsibility on the contractor for the adequacy of his corrosion work. Such contractual relationships would not alter the legal relationship between this Office and the operator, but it could establish the basis for legal actions between the operator and contractor.

The Office of Operations and Enforcement has a Regional Office in Burlingame, California, that is responsible for inspecting operators and assuring compliance with the regulations. Because of the limited staff, their primary inspection efforts are aimed at distribution systems and, to a lesser degree, master meter systems.

Thank you for your interest in matters of pipeline safety.



Robert L. Paullin

Associate Director for

Operations & Enforcement

Materials Transportation Bureau

Regulation Sections

Section Subject
192.453 General