On December 8, 2025, PHMSA issued a Notice of Limited Enforcement Discretion related to the Direct Final Rule titled “Pipeline Safety: Standards Update—API RP 1170 and API RP 1171.”
The rule, originally published on July 1, 2025, incorporates the second editions of API RP 1170 and API RP 1171 into 49 CFR Part 192, with an effective date of January 1, 2026.
Following requests from the American Gas Association and the Interstate Natural Gas Association of America, PHMSA recognized that operators and regulators need additional time to update procedures, complete training, and revise documentation. In response, PHMSA will exercise enforcement discretion through January 1, 2027.
During this period, PHMSA will not take enforcement action related to the Direct Final Rule as long as operators comply with either the first or second editions of API RP 1170 and API RP 1171. This approach is intended to support orderly implementation of the updated standards while maintaining an equivalent level of safety, particularly during upcoming winter heating seasons.
PHMSA has also encouraged state pipeline safety partners to apply the same enforcement discretion. This notice does not relieve operators from compliance with other applicable regulations, and PHMSA retains the authority to take enforcement action if significant safety concerns arise.
As operators work through these updates, TaskOp’s built-in Underground Gas Storage module can help manage API RP 1170 and 1171 requirements by organizing procedures, tracking changes, and centralizing documentation in one system. Click here for more information about the UGS module in TaskOp and feel free to contact Jessica Foley for a copy of the notice.