Over the past two weeks, three significant regulatory updates have been issued that pipeline operators should track closely. First, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published in the Federal Register a Final Rule titled “Periodic Standards Update II” (Final Rule), which incorporates by reference 19 updated industry standards and clarifies several regulatory provisions. Second, PHMSA released updated hazardous liquid high consequence area (HCA) data layers through the National Pipeline Mapping System (NPMS). Finally, the Department of Transportation (DOT) issued a notice of proposed rulemaking (NPRM) on drug-and-alcohol (D&A) testing requirements that will affect PHMSA-jurisdictional operators.
These updates carry both near-term compliance steps and longer-term program implications. Below, we break down each development and highlight the actions pipeline operators should consider.
Periodic Standards Update II Final Rule
On September 10, PHMSA finalized its Periodic Standards Update II, a follow-up to its August 2022 NPRM. This rule incorporates by reference 19 updated industry standards, introduces clarifying edits to existing regulatory language, and replaces several outdated references. Importantly, these updates are in addition to those adopted earlier this year in PHMSA’s June 2025 direct final rule.
The new rule also makes a key update to “49 CFR Part 192, Appendix G,” which provides guidance on identifying moderate consequence areas (MCAs). Where operators once had to cross-reference definitions from the Federal Highway Administration (FHWA), Appendix G now consolidates key roadway classifications — including “other principal arterial,” “minor arterials,” and “major and minor collectors” — directly within PHMSA’s regulatory framework. This move is intended to simplify compliance and reduce reliance on external FHWA publications.
The Final Rule will take effect on January 10, 2026, giving operators about three months to review and align their integrity, construction, and maintenance programs with the updated references.
Standards Incorporated by Reference
The updated standards are grouped by their issuing organizations, with highlights including:
- American Petroleum Institute (API)
- API RP 652, Linings of Aboveground Petroleum Storage Tank Bottoms, 5th Edition (2020)
- API RP 2003, Protection Against Ignitions Arising out of Static, Lightning, and Stray Currents, 8th Edition (2015, reaffirmed 2020)
- API Spec 12F, Shop-welded Tanks for Storage of Production Liquids, 13th Edition (2019)
- API 510, Pressure Vessel Inspection Code, 10th Edition (2014 with 2017 addendum)
- API Std 2510, Design and Construction of LPG Installations, 9th Edition (2020)
- American Society of Mechanical Engineers (ASME)
- ASME B16.40-2019, Thermoplastic Gas Shutoffs and Valves
- ASME B31.4-2019, Pipeline Transportation Systems for Liquids and Slurries
- American Society for Nondestructive Testing (ASNT)
- ANSI/ASNT ILI-PQ-2017, In-line Inspection Personnel Qualification
- Association for Materials Protection and Performance (AMPP, formerly NACE)
- NACE SP0102-2017, In-Line Inspection of Pipelines
- ASTM International
- Updates across a wide range of material, fitting, and welding standards, including ASTM D2513-20 (Polyethylene Gas Pressure Pipe) and ASTM F2620-20ae2 (Heat Fusion Joining of Polyethylene Pipe and Fittings)
- National Fire Protection Association (NFPA)
- NFPA 30, Flammable and Combustible Liquids Code, 2021 Edition
For operators, the incorporation of these standards means more than just updating library shelves. In many cases, design, inspection, and qualification practices will need to be revisited. Engineering groups should begin reviewing project specifications, while compliance teams should map out any implementation gaps ahead of the January 2026 effective date.
Hazardous Liquid HCA Layer Updates
PHMSA has also updated its hazardous liquid HCA mapping layers, a critical input for integrity management program (IMP) requirements under 49 CFR Part 195.
The new release includes Version 6 of the high population area and other population area GIS layers. In addition, Ecological Unusually Sensitive Area data has been updated and is now available either by request or via the operator viewer in PIMMA (PHMSA’s Pipeline Integrity Management Mapping Application).
These HCA layers form the baseline against which operators must compare their pipeline centerlines to determine whether their assets could affect identified HCAs. In turn, those determinations drive IMP obligations, assessment schedules, and remediation priorities.
Operators should take the following actions in response to the new layers:
- Download and review the updated datasets from NPMS or PIMMA
- Reevaluate HCA determinations regarding hazardous liquid assets, paying particular attention to whether new population growth or ecological features have altered coverage
- Document changes to pipeline mileage within HCAs, since total HCA footage often ties directly into annual reporting and inspection schedules
While no formal compliance deadline accompanies these updates, regulators expect operators to maintain HCA analyses that are both current and accurate. Reviewing these datasets promptly will help avoid discrepancies during future inspections.
DOT NPRM on Drug & Alcohol Testing
Finally, the DOT issued an NPRM to amend 49 CFR Part 40, which governs drug-testing procedures for transportation workplaces.
The NPRM would:
- Add fentanyl and norfentanyl to DOT’s drug-testing panel
- Harmonize with HHS Mandatory Guidelines where appropriate
- Clarify existing provisions within Part 40 and implement technical amendments
For pipeline operators, the connection lies in 49 CFR Part 199, which incorporates DOT’s Part 40 by reference for PHMSA-regulated entities. In practice, this means that once Part 40 is amended, operators must update their D&A testing programs accordingly.
Key Considerations for Operators
- Testing panels: Current policies will need to be revised to capture fentanyl/norfentanyl once the rule is finalized
- Program alignment: Operators should begin coordinating with third-party testing administrators and medical review officers to understand potential implementation impacts
- Comment deadline: Stakeholders have until October 17, to submit comments to DOT. Operators who anticipate operational challenges (e.g., with testing technology, false positives, or workforce communication) may want to provide feedback before the rule is finalized
This NPRM reflects DOT’s broader efforts to address the opioid epidemic and ensure that transportation workplaces — including pipeline operations — remain safe and drug free.
Practical Takeaways
The past two weeks have brought a surge of federal activity, and pipeline operators should move quickly to get ahead of the curve:
- Review the Final Rule: Assign engineering and compliance teams to review the 19 updated standards and assess whether construction, inspection, and maintenance practices will need revision before January 2026.
- Update HCA analyses: Download the new NPMS datasets, update HCA determinations, and document any changes for regulatory reporting and IMP compliance.
- Prepare for D&A program changes: Monitor the DOT NPRM; consider filing comments by October 17; and start planning for potential program revisions once fentanyl and norfentanyl are formally added to the testing panel.
By staying proactive on these fronts, operators can reduce compliance risk, streamline implementation, and demonstrate to regulators a strong culture of safety and accountability.
Conclusion
Regulatory changes often arrive in clusters, and this month is no exception. With PHMSA’s incorporation of new industry standards, the updated HCA mapping layers, and DOT’s proposed drug testing amendments, pipeline operators face a range of near- and medium-term compliance tasks. Monitoring these updates closely — and mobilizing teams to address them early — will position operators to stay ahead of enforcement deadlines and maintain safe, compliant operations.
