Regulatory Roundup - Advisory Bulletins, OMB, Enforcement Discretion, LNG Initiatives
PHMSA has issued four Advisory Bulletins, one OMB update, one Special Permit Enforcement Discretion, and several LNG initiatives since mid January. Elemental is summarizing them all for you here. Subscribe to our Newsletter to get updates straight to your inbox.
Advisory Bulletin - Distribution Integrity Management Program Considerations for Plastic Piping and Components
On January 23, 2026 PHMSA published an Advisory Bulletin (ADB) based on findings from the West Reading, Pennsylvania incident. Findings from that incident show a plastic tee exposed to elevated temperatures unknowingly caused material degradation and cracking, which allowed gas to leak and migrate under the building. PHMSA is advising operators to perform a one-time inventory of plastic assets that are at risk of elevation temperatures due to their environment and address risks associated with Aldyl A service tees with Delrin inserts by remediating or replacing them.
The ADB recommends the following actions:
Review Investigation Report
Review previous ADBs on plastic pipe
Develop and implement an IM to identify design and operations, such as plastics and exposure to environmental factors like heat to assess threats to gas distribution lines
Consider environmental factors such as heat and which may by susceptible to low crack growth or brittle-like cracking, or accelerated degradation. Susceptible pipe may include:
1960-1980s installations of plastic pipe
Low-ductile inner wall Aldyl A pipeline manufactured by DuPont before 1973
Polyethylene gas pipe designated PE 3306
Aldyl A tees with Delrin polyacetal insert
Plexco service tee Celcon (Polyacetal) caps
Driscopipe 7000 and 8000 High Density Polyethylene Pipe
Where elevated temperatures may be present, collect additional information to assess the threat and develop a plan for further information collection
Evaluate and rank risks of plastic assets that could experience elevated temperatures
Identify and implement measures to reduce risk, including an effective leak management program. Other measures may include replacement, remediation, opportunistic material type verification, or additional leak surveys.
Maintain records for at least 10 years in accordance with 49 CFR 192 Subpart P
During construction, maintain sufficient clearance or insulation from heat sources
Advisory Bulletin - Integrity Risks of Type A Repair Sleeves
On January 28, 2026 PHMSA published an Advisory Bulletin advising hazardous liquid operators of the integrity risks of using Type A sleeves for pipeline repairs, including:
Increased corrosion risk due to potential for water intrusion and possible cathodic shielding (minimized by reducing annular space and properly sealing the end of the sleeve)
Pressure cycling potential increases especially at ends of Type A sleeves where stress concentration is more likely to occur
PHMSA’s recommended actions to manage Type A sleeve integrity are:
Record Maintenance and Confirmation
Maintenance record evaluation for details of sleeve installation
Searching for additional data if records are missing
Review of ILI Data
Confirm all Type A sleeve locations
Verify that installation records exist for all Type A sleeves
Verify that vendors do not automatically deem anomalies under Type A sleeves as not an integrity threat
If ILI data is not accurate and reliable at sleeve locations, immediately assess integrity at the sleeve installation site
Inventory and Interactive Threat Assessment – Type A sleeves should be considered a possible integrity threat
Create a list of all Type A sleeves and whether they are temporary or permanent
Risk models should account for interactive threats, especially as they relate to Type A sleeves
Fatigue Evaluation – An engineering fatigue analysis should be conducted for Type A sleeves subjected to frequent pressure cycles
Enhanced Leak Detection and Monitoring
Conduct targeted leak surveys in areas of Type A sleeves
Rigorously investigate all leak complaints
Consider enhanced leak detection methods
Review static testing procedures and update to be able to test small pipe segments to identify small leaks
Consider additional continuous leak detection methods (i.e., acoustic balls, fiber optics)
Mechanical and Installation Standards – Ensure Type A sleeve installation procedures follow requirements in:
49 CFR 195, Transportation of Hazardous Liquids by Pipeline
API RP 1160, Standards for Hazardous Liquid Pipeline Integrity
API RP 2201, Safe Hot Tapping Practices in the Petroleum and Petrochemical Industries
ASME B31.4, Pipeline Transportation Systems for Liquids and Slurries
Advisory Bulletin - Protecting Pipeline Integrity During Extreme Winter Weather, Rapid Thaw, and Geohazard Events
On February 11, 2026 PHMSA published an Advisory Bulletin to highlight safety risks associated with the extreme weather much of the country has been experiencing. In addition to the items listed herein, PHMSA reminds operators of the requirements of 49 CFR 192.613 and 195.401 for continuing surveillance following extreme weather events.
Part I details the safety threats associated with the extreme weather and includes:
Heavy snowfall and ice accumulation
Rapid winter thaw and flooding
Scour and erosion
Buoyancy
Frost heave and ground movement
Unusual stress/strain
Geohazard impact
Ice expansion
Part II discusses recommended actions for operators to take to prevent and mitigate those safety threats. Recommended actions include:
Accelerate field patrols
Monitor unusual cold zones
Review geohazard plans
Inspect above-ground facilities
Winterize above-ground facilities
Communication with emergency responders
Advisory Bulletin - Incident Notifications to the National Response Center
On February 20, 2026 PHMSA published an Advisory Bulletin reminding operators of gas pipelines, underground natural gas storage (UNGS) facilities, and liquefied natural gas (LNG) facilities of their obligation to report incidents. The ADB is a response to the National Transportation Safety Board’s (NTSB’s) recommendations from a 2018 fatal incident and two preceding incidents that were not reported.
It includes a recommendation to expand incident reporting even if the source of gas is unknown. PHMSA reminds operators that confirmed discovery occurs “when it can be reasonably determined, based on information available to the operator at the time a reportable event has occurred, even if only based on a preliminary evaluation.” Operators are also reminded that the regulations require:
Reporting of events that are significant in the judgement of the operators even if they do not meet criteria specified in the regulations
Immediate reporting even if only a preliminary evaluation has been conducted
The reporting threshold of $149,700 does not include gas but does include ancillary costs
Factors that may help determine if an incident is reportable include:
Explosion
Fire
Loss of service
Evacuation of people in the area
Involvement of local emergency response personnel
Degree of media involvement
OMB Updated Reporting Instructions
On February 5, 2026 PHMSA updated the OMB reporting instructions. The primary goal is to clarify the definition of "intentional" vs. "unintentional" gas releases to ensure that safety data accurately reflects equipment failures rather than designed safety functions.
The revision focuses on how operators report gas releases from Relief Valves and Emergency Shutdown Devices (ESDs):
Intentional Releases (Non-Reportable): If a relief valve or ESD system activates at the specified set points (including manufacturer tolerances) and performs as designed, the release is considered intentional. These events would no longer be reported as "incidents" because they do not represent equipment malfunctions.
Unintentional Releases (Reportable): A release remains "unintentional" and reportable if a valve in the release pathway fails to open properly or if the system activates outside of its design parameters.
Safety Oversight: Even if a release is deemed intentional and non-reportable as an "incident," PHMSA notes it may still qualify as an abnormal operation or a safety-related condition requiring internal investigation or other specific reporting under 49 CFR 191.23 or 192.605.
Details of this update can be found in the instructions of these forms:
Gas Distribution Incident Report F7100.1
Gas Transmission, Gathering, and UNGS Incident Report F7100.2
Gas Transmission, Gathering, and UNGS Incident Report F7100.2
Enforcement Discretion - Statement of Policy for Issuing Special Permit in Response to National Emergency
On January 12, PHMSA indicated it was exercising limited Enforcement Discretion in response to Executive Order 14156 (Jan. 20, 2025) declaring a National Energy Emergency. PHMSA is outlining how it will issue Special Permits to support energy transportation in the following areas:
West Coast
Northeast
Alaska
To qualify for this Special Permit relief during the national energy emergency, an operator must:
Prove performing the code requirement worsens the energy emergency
Prove deferral does not create unreasonable safety/environmental risk
Apply within 45 days
The regulated party must demonstrate that performing the required activity would worsen the national energy emergency by:
Adversely impacting energy transportation in the specified regions
Increasing energy prices (especially for low- and fixed-income consumers)
Reducing domestic supply of affordable/reliable energy
Impairing integrity or expansion of national energy infrastructure
The regulated party must demonstrate that deferring the activity will not create an unreasonable risk to:
Public safety
Property
Enforcement
The environment
LNG Initiatives and Webinars
PHMSA’s National Center of Excellence for LNG Safety (National LNG Center) is launching a series of informational webinars for leaders to engage in information-sharing with liquefied natural gas (LNG) stakeholders on leading/best practices.
PHMSA held a meeting on February 10 to discuss its project to develop structured methodologies for managing Process Hazard Analysis (PHA) techniques, such as Hazard and Operability (HAZOP) and Layers of Protection Analysis (LOPA), specifically for Liquefied Natural Gas (LNG) facilities. The project page and report can be found here.
PHMSA held a webinar on February 18 titled - Prioritizing Safety - Best Practices in LNG: Guidelines for Writing Effective Operating and Maintenance Procedures. You can watch the YouTube recording here.
The next meeting is scheduled for March 5. Follow this link to sign up to attend. Research & Development Program: LNG Knowledge Development, Develop Methodologies for Cryogenic and Fireproofing Requirements for LNG Facilities