July 2026 Issue
In This Issue
- PHMSA Releases Gas Transmission Pipelines Repair Criteria NPRM
- PHMSA Advisory Bulletin: Guidance for Enhancing the Effectiveness of Distribution Integrity Management Programs
- PHMSA Seeks Public Comment on Proposed Updates to Pipeline Reporting Forms
- Updated D&A Testing Collection Procedures
- Featured Service
- The Enforcement Corner
- Did You Know?
- Q&A Section
- 2026 Conference News
- PSI Training Schedule
PHMSA Releases Gas Transmission Pipelines Repair Criteria NPRM
On July 8, 2026, PHMSA published a Notice of Proposed Rulemaking (NPRM) that would modernize the federal repair criteria for hazardous liquid and gas transmission pipelines. If adopted, these would be the first significant updates to the repair requirements in nearly 20 years.
The proposal is intended to better align the regulations with current engineering practices, inspection technologies, and repair methods while reducing unnecessary operational disruptions. PHMSA estimates the proposed changes could save pipeline operators approximately $390 million over time by allowing greater flexibility in evaluating and repairing certain pipeline conditions without compromising safety.
Among the proposed changes are updates to repair criteria for dents, gouges, cracks, corrosion, and other anomalies identified during integrity assessments. The rule would also revise repair schedules, clarify existing requirements, and incorporate modern engineering assessment methods that have become common throughout the industry.
This proposed rule follows PHMSA’s 2025 Advance Notice of Proposed Rulemaking, which sought public feedback on opportunities to improve the effectiveness and efficiency of the current repair regulations.
Pipeline operators, engineers, and integrity management professionals should review the proposal carefully to understand how the revisions may affect inspection programs, repair decision-making, and compliance strategies. Comments on the proposed rule are due by September 8, 2026.
Click here to view the full NPRM. If you have any questions, please contact Jessica Foley.
PHMSA Advisory Bulletin: Guidance for Enhancing the Effectiveness of Distribution Integrity Management Programs
PHMSA issued a new Advisory Bulletin (ADB 26-06) to remind owners and operators of gas distribution systems of the distribution integrity management program (DIMP) requirements under 49 CFR part 192, subpart P. The guidance is intended to improve implementation of DIMP risk evaluations by addressing factors such as high-risk infrastructure, interactive threats, and leak management effectiveness. In addition, the guidance urges pipeline operators to adopt the most appropriate risk models for use within their integrity management programs, with full consideration of probabilistic risk models.
The Advisory Bulletin highlights recent updates to The Guide for Gas Transmission, Distribution, and Gathering Piping Systems (ANSI/GPTC Z380.1, 2022 edition) addressing interactive threats, system degradation over time, and leak investigation procedures. For a copy of the Advisory Bulletin or to inquire how RCP can support the review of your company’s DIMP risk assessment methodology, contact Jessica Foley.
PHMSA Seeks Public Comment on Proposed Updates to Pipeline Reporting Forms
PHMSA has proposed revisions to several pipeline safety reporting forms used by gas, hazardous liquid, and carbon dioxide pipeline operators. The updates are intended to improve the quality, consistency, and usefulness of the information submitted to the agency, helping PHMSA better identify safety trends, evaluate risks, and prioritize oversight activities.
Among the proposed changes are updates to incident, accident, and annual reporting forms, along with revisions to the National Pipeline Mapping System (NPMS) information collection. PHMSA states that many of the changes are designed to clarify existing reporting requirements, reduce ambiguity, and capture more complete data without creating significant new reporting burdens for operators.
Pipeline operators should review the proposed revisions to determine whether any changes may affect their reporting processes. Stakeholders have until August 17, 2026, to submit comments before PHMSA considers the updates for final approval.
Click here to view the full NPRM. If you have any questions, please contact Jessica Foley.
Updated D&A Testing Collection Procedures
DOT issued a minor update to its drug and alcohol testing rules to address a temporary gap related to oral fluid testing.
While oral fluid testing was approved in a previous rule, it cannot yet be used because certified laboratories are not in place. This update ensures that in situations where oral fluid testing would have been required, employers should continue using directly observed urine testing for now.
Once oral fluid testing becomes fully available, DOT will allow an 18-month transition period for employers to implement it where needed.
Overall, this update does not change current practices—it simply keeps existing procedures in place until oral fluid testing can be realistically adopted.
Click here to view the full NPRM. If you have any questions, please contact Jessica Foley.
Featured Service
CorrosionIQ is a complete corrosion compliance and integrity management platform for pipeline operators.
From cathodic protection monitoring and CIS surveys to remediation tracking and compliance reporting, CorrosionIQ brings every component of your corrosion program together in a single system.
Collect data, manage inspections, track corrective actions, analyze trends, and demonstrate compliance with confidence.
Everything Your Corrosion Program Needs
CorrosionIQ covers the full corrosion lifecycle:
- Corrosion Work Management
- Cathodic Protection Monitoring
- CIS, DCVG, ACVG & ACCA Surveys
- Corrosion Remediation Tracking
- Corrosion Analytics & Reporting
- Dynamic Alignment Sheets
- GIS Mapping & Spatial Analysis
- Mobile Data Collection
- Compliance Documentation & Audit Support
Whether you’re managing transmission, gathering, distribution, hazardous liquid, or underground storage assets, CorrosionIQ provides a single source of truth for your entire corrosion program—helping your team spend less time managing data and more time protecting pipeline integrity.
Built for Pipeline Compliance
CorrosionIQ supports corrosion control requirements under 49 CFR Part 192 and 49 CFR Part 195, including:
- Cathodic protection (§192.463, §192.465, §195.573)
- Internal corrosion control (§§192.475–192.476, §195.579)
- Atmospheric inspections (§192.481, §195.583)
- External corrosion control (§§192.451–192.459, §§195.551–195.559)
- Integrity management programs (§§192.907–192.951, §195.452)
- Inline inspection and direct assessment (§192.921, §192.923, §195.452)
- Anomaly evaluation and repair (§192.933, §195.452)
- Reassessment intervals (§192.939, §195.452)
- Recordkeeping and documentation (§192.491, §195.589)
All requirements are tracked, scheduled, and documented in one place.
Why It Works
Most corrosion programs are spread across multiple systems. CorrosionIQ brings everything together so your team can:
- See the full picture
- Identify risk earlier
- Manage work in one place
- Reduce manual effort
- Stay compliant without the scramble
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 2026, PHMSA issued 1 CAO, 2 NOA, 0 NOPVs, and 3 WLs accompanied by $0 in proposed fines.
Please note:
- Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA.
- Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
- 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.
- A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
- 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.
- A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
- Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
- 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.
Did You Know?
Many PHMSA enforcement cases stem from documentation deficiencies rather than physical pipeline defects. If an operator cannot demonstrate compliance through records, PHMSA may determine the requirement was not met.
Click here to learn more.
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: When does PHMSA consider a pipeline to be “abandoned” rather than “out of service”?
A: A pipeline that is temporarily out of service is not necessarily abandoned. PHMSA considers factors such as the operator’s intent, whether the pipeline may return to service, and whether the abandonment requirements in the regulations have been completed. Operators should document the status of out-of-service pipelines and ensure they meet all applicable regulatory requirements.
Ask the Experts
Do you have a question for the experts at RCP? Submit your question using this form. If your question is selected for a future newsletter, you will be eligible for a gift of your choice from RCP’s online Store.
Upcoming Deadlines:
- And as a reminder, the “Stay of Enforcement” does not mean regulators don’t expect work toward getting compliance activities in place can be ignored.
If we can help, contact Jessica Foley.
2026 Conference News
Western Regional Gas Conference
August 25-26, 2026 | Scottsdale Resort | Scottsdale, AZ
The 2026 Western Regional Gas Conference (WRGC) will take place August 25–26 at The Scottsdale Resort at McCormick Ranch in Scottsdale, Arizona. This nonprofit, volunteer-organized event brings together natural gas distribution and transmission professionals, regulators, and vendors for two days of industry education and networking. Topics will include PHMSA rulemaking updates, DIMP, integrity management, emergency response, Pipeline Safety Management Systems (PSMS), corrosion control, and Pipeline Safety Act reauthorization. PHMSA Administrator Paul Roberti will deliver the keynote address, and RCP’s Chris McLaren & John Gale will provide updates on the regulatory agenda, PHMSA rulemaking, DIMP, the Plastic Pipe Rule, and other key topics.
Click here to register for this event.
We’re Exhibiting & Speaking!
Join RCP at the Western Regional Gas Conference. John Gale, Chris McLaren, and Randall Rogers will be on-site throughout the event and look forward to connecting with attendees.
Be sure to attend Chris McLaren & John Gale’s presentations:
Pipeline Safety Rulemaking Updates, Notices, and Advisories: Perspectives
on PHMSA Rulemaking and the 2026 Reauthorization
Tuesday, August 25 at 9:05AM
Using Your DIMP and IMP Plans to Justify Proposed Pipeline System
Replacements in Rate Cases
Wednesday, August 26 at 8:15AM
GPA Midstream Convention
September 20-23, 2026 | San Antonio Marriott Rivercenter on the River Walk | San Antonio, TX
This gathering is the ultimate destination for more than 1,800 midstream professionals from around the world. It’s your chance to connect, collaborate, and explore the latest industry trends and innovations.
Whether you’re an entry-level engineer, a seasoned technical expert, or a C-suite executive, the GPA Midstream Convention has something for everyone. Our diverse attendees hail from leading operating and supplier companies, ensuring a rich exchange of ideas and opportunities.
Click here to register for this event.
We’re Speaking!
Be sure to attend Chris McLaren’s presentation:
DOT Regulatory Update: PHMSA Priorities, Enforcement Trends, and the PIPES Act of 2026/ PHMSA and RRC Enforcement Trends and Updates
Monday, September 21 at 1PM
PSI Training Schedule
\|
DATE |
COURSE | FEE |
| Nov. 17-19, 2026 |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199) |
$2,150 |
WEBINAR RECORDING!
Unpacking the Key Updates in API RP 1170 & 1171, 2nd Edition
| RCP and the Pipeline Safety Institute offered a free webinar exploring the 2nd Editions of API RP 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage and API RP 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs. Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel! |
WEBINAR RECORDING
Pipeline Safety: Unpacking the Class Location Change Requirements
Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!
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.
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…
On-Site Training Request
We have conducted on-site training for oil and gas companies for over 25 years and can provide customized workshops for companies with groups of five or more.
We would welcome the opportunity to discuss our services with you.
Sincerely,
W. R. (Bill) Byrd, PE
President
RCP Inc.