DOT Pipeline Compliance News

August 2025 Issue

In This Issue

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PHMSA to Hold a Public Meeting to Discuss Pipeline Data

PHMSA has announced a public meeting to discuss how data collected from pipeline operators can be used to improve pipeline and public safety. Discussion topics include how data collected by PHMSA is currently used by stakeholders, displayed on the PHMSA website, and used to generate pipeline safety performance measures. PHMSA is also interested in identifying data that is collected but not used by any stakeholders, as well as data that should be collected but is not. The meeting will be recorded but there will not be a live webcast.

The public meeting on pipeline data will be held on Thursday, September 18, 2025, from 8:00 a.m. to
5:00 p.m. CST, and Friday, September 19, 2025, from 8:00 a.m. to 5:00 p.m. CST. The recordings from this meeting will be available after the meeting on the registration site. Click here to visit the registration site and to see more information about this meeting.

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USDOT Introduces Data-Driven Enforcement Priorities to Strengthen Pipeline Safety

On July 22, 2025, PHMSA announced pipeline inspection and enforcement (I&E) priorities.  This is something new for PHMSA.  The memo directs PHMSA I&E staff to concentrate their efforts on five priority areas:

• Incidents and Accidents;
• High and Moderate Consequence Areas;
• Control Room Management and Leak Detection;
• Damage Prevention; and 
• Transactions and Due Diligence.

PHMSA I&E staff will also prioritize inspections to confirm operator compliance with recent rulemakings. These include requirements for:

• rupture mitigation valves,
• verification of pipeline materials,
• reconfirmation of Maximum Allowable Operating Pressure, and
• Underground Natural Gas Storage facility safety. 

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Missouri Enacts New Standards for Safe Digging

Missouri Governor Mike Kehoe on Monday signed SB133, intended to reduce the risk of damage to the state’s buried utility lines, the type of incident that caused the fatal April 9 explosion in Lexington. The bill adopts Common Ground Alliance (CGA) Best Practices for properly marking buried utilities in advance of digging.

The NTSB’s Initial Report determined the incident was caused in part by damage to an unlocated, unmarked buried natural gas line. The bill will significantly improve damage prevention practices to protect all Missouri residents.

The changes will take effect in August and include:

• Defines damage prevention best practices as CGA Best Practices
• Improves 811 center leadership by including board directors from the construction industry
• Requires all buried utilities installed after August 28, 2025, to include detectable locating devices
• Limits damage liability for excavators if proper procedures were followed             
• Expands presumption of negligence for failing to properly mark buried utilities

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PHMSA Published 28 Separate Rulemaking Actions Affecting the Pipeline Safety Regulations

To further the Administration’s deregulatory policies, PHMSA has published in today’s Federal Register twenty-eight (28) separate rulemaking actions affecting the pipeline safety regulations (PSR; Parts 190-199). Click here to access the documents.  

These actions are summarized below:

1. Pipeline Safety: Rationalize Special Permit Conditions
   Notice of proposed Rulemaking (NPRM)
   49 CFR Part 190
   
   PHMSA proposes to amend its procedures governing special permits authorizing waiver of its pipeline safety regulations to ensure that special permit conditions must be connected directly to the provisions of the pipeline safety regulations being waived.

2. Pipeline Safety: Rationalize Calculation of Regulatory Filing and Compliance Deadlines
   Direct Final Rule (DFR)
   49 CFR Part 190
   
   PHMSA will amend its pipeline safety regulations to introduce a clarification that filing and compliance deadlines falling on weekends and Federal holidays will be adjusted automatically to the following business day.

3. Pipeline Safety: Adjust Annual Report Filing Timelines
   DFR
   49 CFR Parts 191
   
   PHMSA will amend its annual reporting to change the deadline for submission of annual reports from March to June for gas pipelines.

4. Pipeline Safety: Property Damage Definition for Incident Reporting on Gas Pipelines and Accidents on Hazardous Liquid Pipelines
   DFR
   49 CFR Part 191 and Part 195
   
   PHMSA will finalize a previous proposal to clarify, for the purposes of defining an incident on a gas pipeline, the approach specified in regulations for calculating property damage to exclude the costs associated with removing and replacing pavement and certain other inconsequential costs.  PHMSA will also update the monetary damages threshold for accident reporting on hazardous liquid pipelines to align with an inflation-adjusted formula specified in its regulations governing gas pipeline incident reporting.

5. Pipeline Safety: Exception for In-Plant Piping Systems
   NPRM 49 CFR Part 192
   
   PHMSA proposes to amend its regulations to clarify that PHMSA clarify that in-plant piping systems are not regulated.

6. Pipeline Safety: Codify Enforcement Discretion on Incidental Gathering Lines
   NPRM
   49 CFR Part 192
   
   PHMSA proposes to codify a statement of limited enforcement discretion clarifying that a restriction introduced in the previous administration on gas gathering line operators’ ability to invoke the historical “incidental gathering line” applies only to newly constructed lines. 

7. Pipeline Safety: Eliminating Burdensome and Duplicative Deadlines for Gas Pipeline Coating Damage Assessments and Remedial Actions
   NPRM
   49 CFR Part 192
   
   PHMSA proposes to eliminate unnecessarily prescriptive and burdensome deadlines on gas transmission and certain gas gathering lines for completing each of coating damage assessments following trench backfilling of newly installed pipe and remedial actions following failed coating assessments.  The proposal would replace those existing requirements with a general requirement to complete, prior to the in-service date of the pipeline, any coating damage assessments for newly installed pipe, as well as remedial actions undertaken in response to a failed coating damage assessment. 
   
   For expert clarification on this rule, click here to view our Q&A article.

8. Pipeline Safety: Atmospheric Corrosion Reassessment for Pipeline Replacements
   NPRM
   49 CFR Part 192
   
   PHMSA proposes to eliminate an existing requirement for a 3-year atmospheric corrosion reassessment interval for gas transmission and certain gas gathering lines following replacement of pipeline segments or components undertaken in response to a previous identification of atmospheric corrosion.  Pipeline operators replacing pipe would instead be able to employ on that replacement pipeline segment or segments the default 5-year reassessment interval provided for elsewhere in PHMSA regulations.

9. Pipeline Safety: Harmonize Class Change Pressure Test Requirements with Subpart J Pressure Test Requirements
   NPRM
   49 CFR Part 192
   
   PHMSA will align the minimum pressure testing duration (currently 8 hours) for verification of maximum allowable operating pressure (MAOP) following a change in class location on certain short segments of pipe to align with longstanding pressure test duration requirements (4 hours) elsewhere in PHMSA regulations at Part 192, Subpart J.

10. Pipeline Safety: Clarifying Recordkeeping Requirements for Testing in MAOP Reconfirmation Regulation 
    Final Rule – Technical Correction
    49 CFR Part 192
    
    PHMSA will issue a technical correction to 192.624(a)(1) to clarify the ability of gas transmission operators to rely on pressure testing data pre-dating the introduction of the Pipeline Safety Regulations in the early 1970s when re-confirming MAOP on their lines. 

11. Pipeline Safety: Integration of Innovative Remote Sensing Technologies for Right-of-Way Patrols on Gas and Hazardous Liquid Pipelines
    DFR
    49 CFR Parts 192 and 195
    
    PHMSA will amend its regulations governing performance of right-of-way patrols on gas and hazardous liquid pipelines to state explicitly that such patrols may be completed with unmanned aircraft systems, satellites, and other suitable technologies.

12. Pipeline Safety: Periodic Updates of Regulatory References to Technical Standards and Miscellaneous Amendments; Additional Technical Amendments; Response to Petition for Reconsideration
    Final Rule – Technical Correction
    49 CFR Part 192
    
    PHMSA will, in response to a petition for reconsideration from industry stakeholders, amend its regulations governing gas pipelines to incorporate by reference an updated version of a consensus industry standard omitted from the final rule in that proceeding due to then-pending litigation on another PHMSA rulemaking.

13. Pipeline Safety Program: Update of Standards Incorporated by Reference
    Multiple DFRs
    49 CFR Parts 192 and 195
    
    PHMSA issued 16 additional DFRs that each adopt an updated edition of an industry consensus standard replacing an obsolete edition that is incorporated currently by reference in 49 CFR Parts 192 and 195.
    
    The following standards are addressed in this effort:
    – API 6D
    – API 1170 and 1171 UNGS
    – API 620
    – API 2026
    – ASTM A53/A53M etc. (gas and liquid)
    – ASTM A381 (gas and liquid)
    – ASTM F2145
    – ASTM F2600
    – ASTM F2767
    – ASTM A578/A578M
    – ASTM F2817
    – ASTM F2945
    – ASTM F1973
    – NFPA 70
    – PPI TR-3
    – PPI TR-4

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Regulatory Watch: Key Dates & Deadlines

Welcome to Regulatory Watch! In this monthly update, we’ll keep you informed on proposed rule comment periods, effective dates, and upcoming deadlines for various compliance requirements.

Have questions about an upcoming deadline? Please reach out to Jessica Foley for assistance!

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Featured Service

TaskOp Highlight: MOC Module

TaskOp, RCP’s reliable Workflow & Asset Management Application, features a fully integrated Management of Change (MOC) module. Designed to meet the requirements of 49 CFR 192, 195, and PHMSA’s RIN2, Gas Mega Rule regulations as documented in § 192.13, this module allows users to electronically oversee their company’s management of change process.

TaskOp’s MOC module was built to manage the following aspects of any MOC process:

• Scalable approval process, with designated alternates
• Tracking of MOCs through a step-by-step process flow
• Set automatic notifications to key personnel for each process step
• Allows MOC Coordinator to track real time updates and progress of MOC
• Provides checks and balances for modifications of process to ensure MOC security
• Comprehensive documentation of change (TVC)

TaskOp’s MOC module was specifically designed to provide ease of use while being flexible and scalable, offering robust customization options to meet increasing regulatory requirements. This module ensures a consistent and reliable experience throughout any MOC process.

If your goal is a streamlined and accessible MOC process, look no further than TaskOp’s MOC module.

From 49 CFR 192.13: “For pipeline segments other than those covered in subpart O of this part, this management of change process must be implemented by February 26, 2024. The requirements of this paragraph (d) do not apply to gas gathering pipelines.”

To learn more about the TaskOp MOC module, click the link below to schedule a demo.

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The Enforcement Corner

The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations.

In June 2025, PHMSA issued 1 NOA, 3 NOPVs, and 2 WLs accompanied by $188,600 in proposed fines.

• $23,100 – §192.446(e)(2) – Alarm Management
• $39,100 – §195.583(b) – Atmospheric Corrosion Control
• $22,400 – §195.402(a) – Procedure Manual
• $53,900 – §192.907(a) – Integrity Management Program
• $50,100 – §192.446(c)(2) – Control Room Management

Please note:

1. Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA. 
2. Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
3. A Corrective Action Order (CAO) usually addresses urgent situations arising out of an accident, spill, or other significant, immediate, or imminent safety or environmental concerns.
4. A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
5. A Notice of Proposed Safety Order (PSO) addresses pipeline integrity risks that may not constitute a hazardous facility requiring immediate corrective action (see Corrective Action Order described above), but do need to be addressed over time.
6. A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
7. Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
8. Warning Letter (WL) is an official notice by PHMSA that an operator needs to make improvements but that no further enforcement is proposed for those findings at this time.

RCP maintains a detailed database of all PHMSA enforcement actions dating back to 2007 and is routinely asked for data analysis of various enforcement actions. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.

Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course? 
RCP maintains a detailed database of all PHMSA enforcement actions and their resolution which enables us to compare and contrast individual enforcement actions to nationwide actions and trends.  We can help put things into context to ensure an effective reply for each citation.  For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.

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Q&A Section

Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators regarding interpretations and pending regulatory deadlines.

Q:  The proposed PHMSA language states that we still have to do a post construction coating check within 6 months. It just moved the “start date” of that 6 months from “backfill” to “in-service date”. It doesn’t look like we can avoid the coating check after construction. Check the proposed language of 192.319(d)

A: Yes, you still have to do a coating evaluation but it’s from in-service, not the date the line was buried.

Ask the Experts

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Did You Know?

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2025 Conference News

APGA Operations Conference 2025
October 21-October 23, 2025 | Sheraton Hotel Charlotte | Charlotte, NC

This event typically attracts over 250 natural gas distribution industry professionals from more than 70 public gas systems to learn about topics such as PHMSA’s Natural Gas Distribution Infrastructure Safety and Modernization Grant Program, methane emission mitigation strategies, and new technology along with an exhibitor hall. 

Click here to register for APGA’s Operations Conference.

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2025 PSI Training Schedule

DATE	COURSE	LOCATION
Nov 18-20, 2025	Advanced DOT Pipeline Compliance Workshop (49 CFR 192 and 195)	Houston, TX
Jan 27-29, 2026	DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 and 199)	Houston, TX
On-Demand	DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 and 199)	Online
On-Demand	Fundamentals of Pipeline Pressure Testing (Gas & Liquid Pipelines)	Online

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You asked and we listened!

Advanced DOT Pipeline Compliance Workshop is on the calendar!

This intensive and interactive 3-day, in-person workshop is designed for those who have previously completed our DOT Pipeline Compliance Workshop and are ready to take their knowledge to the next level.

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New Workshop Alert!

Prepare Your Team for Pipeline Safety Audits with Confidence!

Our 3-day Pipeline Safety Audit Workshop is tailored for professionals responsible for the safe operation of hazardous liquid and natural gas pipelines. Designed for groups of 10-15 participants, this interactive training…

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We would welcome the opportunity to discuss our services with you.

Sincerely,

W. R. (Bill) Byrd, PE
President
RCP Inc.