PHMSA Issues Final Rule for Class Location Change Requirements
PHMSA has issued a Final Rule, scheduled to be published to the Federal Register tomorrow, January 14, 2026. PHMSA is modernizing how gas transmission operators may manage class location changes under 49 CFR Part 192. The rule codifies a risk-based approach that PHMSA has relied on for more than two decades through special permits.
The original gas pipeline safety regulations published in 1970 adopted concepts from the American Standard Code for Pressure Piping, Section 8, Gas Transmission and Distribution Piping Systems, ASA B31.1.8 (B31.8). These concepts include the idea of Class Locations, how to establish Maximum Allowable Operating Pressure (MAOP), and recurring studies to identify changes in Class Location. The 1970 rule also included more stringent operation and maintenance (O&M) requirements as the Class Location increased in value and required a reevaluation of MAOP should the Class Location change on a particular segment.
After adopting the integrity management (IM) program for gas transmission lines in the early 2000s, PHMSA established a new policy for granting special permits (or waivers) of the requirements for addressing class location changes. These special permits permit operators to maintain or restore MAOP using IM principles to manage integrity. PHMSA has granted special permits, requiring operators to comply with a series of additional requirements, to more than 45 operators in the 20 years since issuing that policy, and no pipeline segment subject to a Class Location special permit has experienced a failure.
The new Final Rule formally adopts this approach into regulation, eliminating the need for case-by-case special permits.
Eligible Class 3 segments may confirm MAOP by conforming with Integrity Management requirements under Subpart O and complying with the following additional requirements:
The following initial programmatic requirements must be met no later than March 16, 2028 or within 24 months of the date of class location change:
Perform a baseline assessment and remediate Immediate and 1-year conditions
Pressure test to 1.25x MAOP in accordance with Subpart J
Confirm TVC records for certain pipeline attributes
Use existing or install new RMVs on either end of eligible Class 3 segments
Install (if not existing) at least 1 CP test point with a max spacing of 0.5 miles between points
Perform a Depth of Cover survey and remediate as required
Perform a Coating survey and remediate if certain issues are identified
Notify PHMSA that the MAOP is being confirmed under these rules
The following recurring programmatic requirements must begin no later than March 16, 2028, or 24 months after the date of the class location change:
Meet gas quality specifications
Perform Close Interval surveys every 7 years
Perform ROW patrols monthly
Complete Leakage surveys four times per year
Install line markers
Clear shorted casings
Conduct Class Location studies annually
Perform examinations and remediations when the pipeline is exposed
Complete remediation activities in accordance with Subpart O
Additional requirements include:
Validate ILI results in accordance with API 1163
Do not use Direct Assessment as an integrity assessment method
Use 1.39x factor for MAOP when determining predicted failure pressure on Class 1 pipe in Class 3 segments
Within 2 years of a leak or rupture confirm or revise MAOP
Keep records for life of the pipe
Limit the design factor to a maximum of 72% of SMYS for Class 1 or 60% of SMYS for Class 2
Additionally, the rule amends the HCA definition to include provisions for Class 3 segments with an MAOP confirmed in accordance with 192.611(a)(4).
Certain segments are ineligible for inclusion. For example segments containing bare pipe, wrinkle bends, certain longitudinal seams, or segments with leaks or ruptures due to cracking.
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