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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-79-0103

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: IL Country: US

View the Interpretation Document

Response text:

September 25, 1979

Mr. P. P. Petro
Director – Technical Services
3240 North Mannheim Road
Franklin Park, Illinois 60131

Dear Mr. Petro:
This responds to your letter of July 6, 1979, asking if the rule in 49 CFR 192.281(a), stating that
“plastic pipe may not be joined by a threaded joint or miter joint,” applies to the manufacture of
fittings in a plant.

As indicated by section 192.271(b), neither section 192.281 nor any of the other provisions of
subpart F concerning the joining of materials apply to joining that is performed during the
manufacture of pipe or components (including fittings).  The regulations do apply to any joining of
pipe or components that occurs for gas pipeline transportation purposes outside the manufacturing
factory.  Such joining is normally performed at a pipeline construction site or in fabrication
Sincerely, Cesar De Leon Associate Director for
Pipeline safety Regulation
Pipeline safety Regulation
Materials Transportation Bureau
3240 North Mannheim road
Franklin Park, Illinois 60131

July 6, 1979

Mr. Ceasar De Leon Office of Pipeline Safety Department of Transportation Washington, D. C. 20590

Dear Mr. De Leon:
Our Company is involved in a program of testing and evaluating concepts used in Europe and
Australia for manufacturing polyethylene fittings for pressure pipe applications.

One of the methods used for manufacture of the larger diameter polyethylene pipe fittings is
fabrication of the fitting from pipe by "miter" fusion. The "miter joints" are formed utilizing
special equipment with established and recognized butt fusion techniques.

Since these "miter joint" fittings will most probably be used for transport of natural gas within a
distribution system or a low pressure transmission system covered by the regulations of the Office
of Pipeline. Safety, it is our desire to obtain a clarification of certain segments of Part
192, Title 49, Code of Federal Regulations.

In reviewing the regulations, paragraphs 192.271(b) "This subpart does not apply to joining during
the manufacture of pipe or pipeline components," and 192.281(a) "Plastic pipe may not be joined by
threaded joint or miter joint," we have interpreted these paragraphs to mean that


(a)         the regulations do not apply to the manufacture of fitting in a plant
(b)         the regulations do apply to fabrications in the field
(c)         the products must meet all the appropriate performance requirements of Part

We would appreciate your response to our interpretation of the regulations.
Thank you.
Very truly yours,
P. P. Petro
Director - Technical Services

Regulation Sections

Section Subject
192.271 Scope