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Interpretation Response #PI-92-053 ([Arco Oil and Gas Company] [Brenda Y. Munoz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Arco Oil and Gas Company

Individual Name: Brenda Y. Munoz

Location State: TX Country: US

View the Interpretation Document

Response text:

October 1, 1992

Ms. Brenda Y. Munoz

Regulatory Compliance & Environmental


Arco Oil and Gas Company

P.O. Box 1346

Houston, TX 77251

Dear Ms. Munoz:

Your letter of August 17, 1992, addressed to Richard Rippert of this office describes an offshore LPG pipeline that operates at a stress level of less than 20% of SMYS. You asked whether employees who operator and maintain this pipeline are subject to drug testing under 49 CFR Part 199.

If the line is exempt from Part 195 under § 195.1(b)(3) because of its operating stress level, then the employees who operate and maintain the line are not subject to drug testing under Part 199 unless they also operate and maintain other pipeline facilities which are regulated.

Please note, though, that we have begun a rulemaking proceeding aimed at bringing hazardous liquid pipelines that operate at less than 20% of SMYS under Part 195 (Docket PS-117; 55 FR 45822; October 31, 1990.) This proceeding affects your LPG pipeline. If it were to become subject to Part 195 as a result of that proceeding, employees who operate and maintain the line would be subject to drug testing under Part 199.

We trust this adequately responds to your inquiry.


Cesar De Leon

Director, Regulatory Programs

Office of Pipeline Safety

Regulation Sections

Section Subject
195.1 Which pipelines are covered by this Part?