January wasted no time, and neither did PHMSA. Between a new final rule, fresh enforcement activity, and the early release of the Integrated Audit Question-sets on 12/31/2025, the compliance landscape shifted fast.
Find the IA Question-Sets in Evergreen:AIR™ on the "From PHMSA" tab, with Excel versions available on the "Inspections" tab. The 2026 Integrated Audit Question-sets are also searchable using the :AIR™ "Database Search", making it easier to find exactly what you need.
Here’s a short list of what’s been keeping the compliance world busy!!.
Inside this issue:
PHMSA Final Rule on Class Location Requirements
A breakdown of the new Class Location Change Requirements under 49 CFR Part 192, including the Integrity Management alternative and what’s changed.
Notice of Limited Enforcement Discretion How Pipeline and Hazardous Materials Safety Administration plans to approach enforcement and special permits during the national energy emergency.
PHMSA Report to Congress on NTSB Recommendations A summary of PHMSA’s annual report addressing calendar year 2024 pipeline safety recommendations issued by the National Transportation Safety Board.
PHMSA NOPV Issued for MPOG Pipeline Release Key details from the Notice of Probable Violation, proposed civil penalty, and compliance order related to the Main Pass Oil Gathering pipeline incident.
Breathe in that fresh Evergreen:AIR™ – Your Compliance Compass
James
Pipeline Safety: Class Location Change Requirements
Docket No. PHMSA-2017-0151
Pipeline and Hazardous Materials Safety Administration has issued a final rule updating 49 CFR Part 192 to modify how operators may address class location changes affecting gas transmission pipelines. The rule was issued onJanuary 12th, 2026 and is expected to be published in the Federal Register January 14th, 2026, with an effective date March 15, 2026th.
Summary of the Key Changes
Integrity Management Alternative Added The rule adds a new option at § 192.611(a)(4) allowing operators to manage certain class location changes using a defined Integrity Management (IM) alternative, rather than relying solely on pressure testing, pipe replacement, or MAOP reduction.
New Eligibility Definitions Two new definitions are added to § 192.3:
Eligible Class 3 segment
Eligible Class 3 inspection area
Only pipeline segments meeting the specified eligibility criteria may use the IM alternative.
Expanded Applicability to Class 2 -Class 3 Changes The IM alternative applies to both Class 1 - Class 3 and Class 2 - Class 3 location changes. For Class 2 design pipe, the rule requires maintaining an operating pressure corresponding to no more than 60 percent SMYS when using the IM alternative.
Pressure Test Documentation Requirements Operators must have records of a 1.25 × MAOP pressure test conducted in accordance with Subpart J or complete such a test within the required compliance timeframe for eligible segments.
Programmatic IM Requirements Codified
Eligible segments must be designated as HCAs and incorporated into the operator’s Subpart O Integrity Management program. The rule establishes:
One-time programmatic requirements to be completed within 24 months, and
Ongoing requirements for reassessment, remediation, and supplemental operations and maintenance measures.
Applicability to Past Class Location Changes Operators may apply the IM alternative regardless of when the class location change occurred, including changes that took place prior to the rule’s effective date.
Transition from Special Permits Operators with existing class location special permits may request to discontinue those permits and operate under the IM alternative instead.
Evergreen:AIR™has already created redlines (see below) highlighting exactly what changed. Subscribers can access them now. What are you waiting for? Take it for a spin with a 14-day free trial.
Notice of Limited Enforcement
PHMSA has issued a Notice of Limited Enforcement Discretion and Statement of Policy, outlining how the agency plans to approach enforcement actions and special permit requests during the national energy emergency declared under Executive Order 14156.
For affected operators, this notice provides important flexibility. PHMSA indicates it will generally refrain from enforcement when a required activity is deferred, provided the operator can demonstrate that completing the activity would negatively impact energy transportation in the West Coast, Northeast, or Alaska, that the deferral does not introduce an unreasonable safety risk, and that a special permit application is submitted within 45 days.
PHMSA also notes it will prioritize the review of qualifying special permit applications and will refrain from enforcement while those applications are under review. The policy applies to activities regulated under 49 CFR Parts 190–199 and 171–180. While it does not waive regulatory requirements or carry the force of law, it offers meaningful insight into PHMSA’s current enforcement posture.
PHMSA Submits Report to Congress on NTSB Pipeline Safety Recommendations Calendar Year 2024
Pipeline and Hazardous Materials Safety Administration (PHMSA) has submitted its annual Report to Congress summarizing pipeline safety recommendations issued by the National Transportation Safety Board (NTSB) during calendar year 2024, along with PHMSA’s responses to each recommendation.
The report documents two NTSB pipeline safety recommendations issued to PHMSA in 2024, both of which PHMSA concurred with. One recommendation was closed in October 2024 following enforcement action related to post-accident drug and alcohol testing requirements. The second recommendation was implemented in March 2025 through publication of an advisory bulletin promoting Pipeline Safety Management Systems (PSMS) based on API RP 1173.
The report fulfills PHMSA’s statutory reporting obligation under the Pipeline Safety Improvement Act of 2002 and provides visibility into how NTSB recommendations are tracked, addressed, and closed.
PHMSA has issued a Notice of Probable Violation (NOPV), Proposed Civil Penalty, and Proposed Compliance Order tied to a major offshore crude oil release on the Main Pass Oil Gathering (MPOG) pipeline system in Louisiana state waters.
The action follows a multi-year investigation into a November 2023 failure at Main Pass 69 involving a subsea collet grip flange connector, which resulted in the release of approximately 27,000 barrels of crude oil.
PHMSA alleges multiple probable violations of 49 CFR Part 195, citing issues spanning pipeline design for external loads, integrity management risk evaluation and data analysis, leak detection performance, operating and emergency procedures, control room management, controller training, and valve maintenance.
The agency is proposing a $9,622,054 civil penalty along with a Compliance Order requiring a system-wide technical review of geotechnical and external load risks and a formal remediation plan to address identified vulnerabilities.
The operator has 30 days to respond before PHMSA may issue a Final Order.
Cases like this raise an important question: how early visibility into enforcement trends, cited regulations, and historical context might help operators identify and mitigate risks to their pipelines.
Let’s Connect
Join theEvergreen:AIR™community to see how our tools and our people help operators navigate PHMSA data, interpretations, enforcement actions, and rulemakings all in one place.
You're never on your own. The Evergreen:AIR™team is always here to help. Whether you need research support, key regulatory details, or anything else, just reach out, we’ve got you covered.
