PHMSA's Statement of Policy for HL and CO2 in Non-Steel Lines
On May 19th 2026, PHMSA published a Statement of Policy regarding transporting hazardous liquid and carbon dioxide in non-steel pipelines. This policy appears to be a clarification and loosening of expectations surrounding the transport of hazardous liquid and CO2 in non-steel lines. Subscribe to our Newsletter to get updates straight to your inbox.
Statement of Policy
PHMSA has published a reminder to operators of the requirements under 49 CFR 195.8 requiring that operators seeking to transport hazardous liquid and CO2 in non-steel pipelines must “notify the Administrator in writing at least 90 days before the transportation is to begins”:
The notice to the administrator must include items such as chemical name, common name, properties and characteristics and material used in the construction of the line
The administrator will respond within 90 days if the transport of product would be unduly hazardous directing the operator not to transport until further notice
Operators do not need to obtain a special permit and if the administrator does not object the operator is allowed to transport the product
The statement of policy goes on to outline what criteria PHMSA considers when it is evaluating for “unduly hazardous" including:
If the pipelines constructed with that material have a history of operating safety in other environments
If the material is authorized for use in transporting gas under 49 CFR 192 and if so, whether the operator will comply with design, construction, testing, operating and maintenance requirements under that regulation
When evaluating transport in a pipeline constructed with corrosion-resistant, non-steel material PHMSA considers:
Whether the material is manufactured in conformance with a published specification and documented quality assurance program
PHMSA reaffirmed its awareness of standards related to constructing non-steel lines including API Specification 15S, Spoolable Reinforced Plastic Line, API Specification 15HR, High-Pressure Fiberglass Line Pipe, API Specification 15LR, Low Pressure Fiberglass Line Pipe, ASTM F2619, High-Density Polyethylene Line Pipe, and ASTM F2896, Reinforced Polyethylene Composite Pipe. Additionally, PHMSA noted its awareness of standards relating to the transport of CO2 in non-steel lines including DNV-RP-F104, Design and Operation of Carbon Dioxide Pipelines, and API RP 1192, Transportation of Carbon Dioxide by Pipeline.
The abovementioned standards are not currently incorporated by reference into liquid code however, PHMSA emphasized that if the pipeline was designed, constructed, tested, operated, and maintained in accordance with those standards then it could be done safely. PHMSA also emphasized that a non-steel pipeline may be more appropriate in certain circumstances.
In light of the above PHMSA is issuing a new policy for evaluating notices submitted under 195.8. PHMSA states that the Administrator will refrain from exercising their discretion to issue a prohibition under 195.8 as long as the operator provides “information necessary to demonstrate that the pipeline will be designed, constructed, tested, operated, and maintained in accordance with recognized and generally accepted industry codes and standards.”
PHMSA states it would find the following useful in making a determination:
List of codes and standards the operator plans on using to design, construct, test, operate, and maintain the pipeline
Chemical name, common name, properties and characteristics of the product
Information showing non-steel material is compatible with the product being transported including chemical compatibility, permeation, delamination, effects on elastomers, decompression behavior, fracture behavior, etc.
Expected long-term performance of the non-steel material in the proposed service, including any testing results validating performance at applicable pressures and temperatures for the product being transported
Written procedures the operator intends to follow to ensure compliance with industry codes and standards, manufacturer specifications and instructions, and other accepted engineering practices
Written Integrity Management Plan for lines in High Consequence Areas
Operators must still comply with applicable portions of 49 CFR 190-199 and this policy does not have the force of law. It does give operators a clear path forward for those that wish to use non-steel lines.
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