Interpretation Response #PI-89-021 ([Looper, Reed, Ewing & McGraw Incorporated] [Douglas B. Wyatt])

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

Interpretation Response Details

Response Publish Date: 09/27/1989

Company Name: Looper, Reed, Ewing & McGraw Incorporated

Individual Name: Douglas B. Wyatt

Location State: TX Country: US

View the Interpretation Document

Response text:

Mr. Douglas B. Wyatt

Looper, Reed, Ewing & McGraw Incorporated

Attorneys

Suite 1717

Nine Greenway Plaza

Houston, Texas 77046

Dear Mr. Wyatt:

you requested clarification of our August 31, 1989, letter regarding protection for offshore pipelines. The requirements of 49 CFR 192.317(a) apply to conditions known or that can be foreseen at the time of construction. Thereafter, an operator does not have a continuing obligation under this rule to provide protection against hazards from changed or new conditions. However, if the operator learns the pipeline has become unsafe due to these changed or new conditions, the operator would have to take remedial action as required by 49 CFR 192.703(b).

We would agree that the protection required by §192.317(a) could be any measure considered reasonably necessary to guard against foreseeable damage from a foreseeable event, provided that measure is based on sound engineering judgment.

Sincerely,

/signed/

James C. Thomas

Deputy Director

Office of Pipeline Safety

Regulation Sections