In 2021–2025, about 36 percent of cited items were natural gas (Part 192) and about 54 percent were hazardous liquids (Part 195). Through October 2026, gas is about half of cited items and liquids about 46 percent. The case count moved the same way: 48 natural-gas cases in ten months, more than the 38-case average for a full year in 2021–2025. Hazardous-liquid cases are up by less, 45 in ten months against a full-year average of about 42, and well above the 22 liquid cases in 2025. LNG (Part 193) was cited in 20 cases across those five years and in two cases so far in 2026: a notice of amendment on operating procedures, and a cooldown-rate case (§193.2505(a), $360,300 proposed) in which an operator cooled a cryogenic system faster than its procedure allowed.

Proposed dollars still concentrate on liquids. Hazardous-liquid items are about 77 percent of 2026 proposed penalties, compared with about 62 percent in 2021–2025. The largest of those proposals are procedural-manual and integrity-management cases.

§192.605(a) — follow the operations and maintenance manual. This is the citation operators are seeing most often in 2026, and it is running well ahead of the prior five years: six operators in ten months, against about four operators in a typical full year from 2021 through 2025, and $653,215 proposed, against about $268,000 in a typical prior year. Nineteen items carry the citation. Fourteen of them are one municipal case, each written at $0, for separate failures to follow that operator’s own manual. The proposed dollars are three failure investigations. In one, line markers were missing or obscured before a third-party strike. In another, aerial-patrol logs did not record industrial activity over the right-of-way before a rupture. In a third, the operator did not follow its in-line inspection tool-selection procedure for stress-corrosion cracking, and later did not record the cracking found on buried pipe.

The §192.605(a) summaries from 2021 through 2026 describe the same kind of miss. The manual already required the step. The crew did not do it, or the manual had not been reviewed and the procedures people were using were not in it. The steps that recur are excavation clearance and line markers, right-of-way patrol and leak survey, lockout and de-energizing before maintenance, cathodic-protection reads, odorant sampling, and the annual review of the manual. Several of the largest proposals followed a strike or a rupture in which that skipped step was the one that would have shown the threat. The useful check is to walk the manual against the work orders: the procedure names the task, the crew did it, and the record shows it.

§195.402(a) — the same gap on hazardous liquids. The liquid procedural-manual requirement is where the dollars are. Seven cases in 2026 propose $2.12 million under §195.402(a), against about $660,000 a year on average in 2021–2025. The allegations are field execution ahead of a release. In one case the operator did not shut the line down after a suspected leak in a high-consequence area. In two others, the operator did not follow the maintenance procedure in use in the days around an accident. In another, the operator did not follow its internal-corrosion procedure ahead of three crude-oil releases.

§195.452 — liquid integrity management. These items are running at about three times the 2021–2025 monthly pace: 21 items, 13 operators, about $733,000 proposed. The repeated gaps are naming the segments that can affect a high-consequence area, keeping the records that justify the assessment method, staying inside the assessment interval, and carrying out the preventive step the risk analysis already called for. In one case a geohazard evaluation recommended a reroute on a high-risk erosion segment that could affect a high-consequence area, and the operator did not carry it out.

Public awareness (§192.616) and operator qualification (§192.805) are up in count, with modest proposed amounts. Control-room management (§195.446) is about even with the 2021–2025 pace, so it remains a regular topic. Underground storage (§192.12) is only somewhat more frequent, and the write-ups are still wellhead inspection, valve tests, and risk assessments under API RP 1171. Standalone atmospheric and external corrosion citations are below that earlier pace. Corrosion still appears in 2026, usually as a failure to follow the corrosion procedure in the manual, or as an integrity-management gap such as tool tolerance and remaining strength.