THE REGULATION OF PLASTIC GAS DISTRIBUTION SYSTEMS IN THE U.S. - UPDATES FROM THE PLASTIC PIPE RULE

The U.S. Department of Transportation (DOT) through the Pipeline and Hazardous Materials Safety Administration (PHMSA) promulgates Title 49 Code of Federal Regulations. Part 192 establishes the minimum federal safety standards for the transportation of natural or other gas by pipelines in the U.S. On Nov. 20, 2018 PHMSA published the final so called “Plastics” rule related to the use of plastic gas piping systems. The amended code had an effective date of Jan. 22, 2019 with a mandatory compliance date Dec. 31, 2019. The updated CFR put forth extensive changes impacting how plastic pipe is designed and used in energy applications.

The rulemaking was intended to improve pipeline safety, adopt newer technologies and best practices, and respond to numerous petitions from industry stakeholders. The final rule included new and updated regulations new standards, marking requirements, system design, heat fusion joining, as well as many plastic gas fittings and components. As the industry works to implement the code changes questions around interpretation and application of the amended code in the field have arisen and will affect ongoing code changes.

PHMSA uses a complex process to amend the CFR through iterations of proposed rulemakings and public input, followed by advisory board review and final rule publishing. The Plastics Pipe Institute (PPI) along with numerous trade organizations and industry members take part in the process. This aids in the development of responsible regulations to improve the safety of gas systems through petitions, comments, and public meetings.

This paper will review the relevant code changes, discuss the U.S. federal code development process, and highlight the challenges of implementing the updated PHMSA requirements related to plastic pipelines. In addition, the paper will address possible proposed future regulatory changes impacting plastic pipelines.