On May 19, 2026, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a new policy statement clarifying how the agency intends to evaluate the transportation of hazardous liquids and carbon dioxide in non-steel pipelines.
The policy centers around 49 CFR §195.8, which already allows operators to transport hazardous liquids or carbon dioxide in non-steel pipelines provided they submit written notice to PHMSA at least 90 days before operations begin. The notice must include information about the product being transported, material compatibility, and pipeline construction details.
What makes this policy statement significant is PHMSA’s clear indication that the agency will generally avoid prohibiting these projects when operators can demonstrate that the pipeline will be designed, constructed, operated, and maintained safely and in accordance with recognized industry standards.
PHMSA also reinforced several key principles the agency will consider when reviewing notices, including:
- Compatibility of the non-steel material with the transported product
- Use of recognized industry codes and standards
- Safe operating history of the proposed material
- Compliance with applicable integrity management and operational requirements
- Alignment with applicable portions of 49 CFR Parts 192 and 195 where appropriate
The policy could open the door for operators to evaluate alternative pipeline materials for certain hazardous liquid and carbon dioxide applications, particularly where corrosion resistance, installation efficiency, or lifecycle costs are considerations.
Expert Insight from Bill Byrd
According to Mr. Bill Byrd, President of RCP, the policy statement represents a major shift in how operators may approach non-steel pipeline projects moving forward.
“The key phrase in PHMSA’s policy is that the Administrator will generally refrain from exercising discretion to prohibit the transportation of hazardous liquid or carbon dioxide in a non-steel pipeline. In practical terms, that means approval can largely be assumed when operators provide the proper notification, documentation, material compatibility information, and demonstrate compliance with applicable standards and integrity management requirements.”
Bill also noted that the policy gives operators significantly more flexibility when evaluating future pipeline construction options.
“This policy effectively creates new opportunities for operators to consider alternative pipeline materials in applications where they may not have been viewed as realistic options before.”
RCP’s regulatory and engineering experts can assist operators with notification packages, supporting documentation, procedures, integrity management considerations, and implementation strategies related to non-steel pipeline applications.