The California Office of the State Fire Marshal (OSFM) has proposed new in-line inspection (ILI) requirements for intrastate hazardous liquid pipelines under Title 19 of the California Code of Regulations. The proposal introduces requirements that extend beyond federal regulations under 49 CFR Part 195.

Key provisions include:

• § 2154: Requires most intrastate hazardous liquid pipeline segments to accommodate ILI tools within a five-year compliance framework, including segments outside high consequence areas. Exemption requirements would differ from 49 CFR Part 195.
• § 2156: Allows OSFM to determine the type of ILI tool used in the interest of public safety.
• § 2157(b): Authorizes OSFM to require more frequent integrity assessments.
• § 2158(c): Requires six independent validation measurements, generally before receipt of the final ILI report.
• § 2158(d)(4): Establishes a 12-month repair requirement for metal loss of 40% or greater, regardless of anomaly dimensions.
• § 2159(a)–(b): Establishes minimum operating pressure reductions of 20% for immediate repair conditions and 10% for certain delayed repairs, potentially limiting engineering-based pressure restrictions permitted under federal regulations.
• § 2159(d): Allows OSFM to direct additional remedial actions to ensure pipeline safety.

The proposal also raises concerns regarding differences between OSFM and PHMSA standards incorporated by reference, as well as the extent of OSFM’s authority over operator integrity management decisions.

OSFM issued revised proposed regulations on October 1, 2026. If adopted, these requirements could significantly affect inspection schedules, repair obligations, and compliance costs for California hazardous liquid pipeline operators.

Click here to review the Title 19 requirements. For assistance, please contact Jessica Foley.