News & Analysis as of

PHMSA Regulatory Requirements

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Shipping...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) transmitted a January 27th Interpretive Letter addressing the application of the Hazardous Materials Regulations (“HMR”) applicable to shipping papers. See...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) published a January 14th Interpretive Letter clarifying the Hazardous Materials Regulations (“HMR”) applicable to cargo tanks. See Reference...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a December 22, 2025, Interpretive Letter the application of the Hazardous Materials Regulations (“HMR”) to the transportation of...more

McGuireWoods LLP

Federal Pipeline Agency Opens 2026 With Record Civil Penalty

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Pursuing a record high civil penalty from a pipeline operator involved in a major oil spill, the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) sent a powerful New Year’s message...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 7th Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”) to the term “surfactant”...more

Alston & Bird

PHMSA Seeks Comments on Proposed Rulemaking on Hazardous Materials Transportation by Highly Automated Transport Systems

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The Pipeline and Hazardous Materials Safety Administration (PHMSA) and U.S. Department of Transportation (DOT) published an advance notice of proposed rulemaking...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) sent a December 11th Interpretive Letter to DG Advisor addressing the application of the federal Hazardous Materials Regulations (“HMR”) to what is...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Frac...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a December 8th Interpretive Letter the application of the Hazardous Materials Regulations (“HMR”) to bulk containers commonly...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a September 30th Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”) to the preparation of shipping...more

McGuireWoods LLP

The PIPELINE Safety Act of 2025: What Operators Need to Know

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On Oct. 6, 2025, a bipartisan foursome from the Senate Committee on Commerce, Science, & Transportation introduced the PIPELINE Safety Act of 2025. The proposal aims to “enhance the safety of pipeline transportation” by...more

Steptoe & Johnson PLLC

Three Key Federal Updates Pipeline Operators Need to Track

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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...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Shipping...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) transmitted a September 30th Interpretive Letter clarifying the Hazardous Materials Regulations (“HMR”) applicable to the preparation of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Clarifying the...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an August 7th Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”) to the transportation of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) clarified in an August 12th Interpretive Letter the Hazardous Materials Regulations (“HMR”) applicable to emergency discharge control equipment for...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Pipeline and Hazardous Materials Safety Administration Stakeholder Feedback Solicitation/Elimination of Regulatory Burdens: Energy...

The Energy Marketers Association of America (formerly PMAA, “EMA”) submitted July 29th comments to the Pipeline and Hazardous Materials Safety Administration (“PHMSA”) in response to its stakeholder feedback solicitation on...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: U.S. Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a July 15th Interpretive Letter the application of the Hazardous Materials Regulations (“HMR”) to intermediate bulk containers (“IBCs”). See...more

Mitchell, Williams, Selig, Gates & Woodyard,...

nspection and Enforcement Priorities/Office of Pipeline Safety: Pipeline and Hazardous Materials Safety Administration July 17th...

The Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety (“OPS”) issued a July 17th memorandum titled: Inspection and Enforcement Priorities (“Memorandum”)....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a July 10th Interpretive Letter the application of the Hazardous Materials Regulations (“HMR”) to fissile exceptions for radioactive materials....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a June 5th Interpretive Letter clarifying the Hazardous Materials Regulations (“HMR”) applicable to United Nations specification packaging exceptions...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials Regulations: Pipeline and Hazardous Materials Safety Administration Letter of Interpretation...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a May 2, 2025, Letter of Interpretation (“LOI”) addressing the application of the federal Hazardous Materials Regulations (“HMR”) to the use of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Oil and Gas Waste/Hazardous Materials Regulations: Environmental Organizations Submit Request for Pipeline and Hazardous Materials...

EARTHJUSTICE on behalf of a number of other organizations submitted a June 4th document to three federal agencies styled: Request for Enforcement of Hazardous Materials Laws in U.S. Oil and Gas Fields (“Request”)....more

Steptoe & Johnson PLLC

PHMSA Issues Advance Notice of Proposed Rulemaking Seeking Stakeholder Comments Related to Repair Criteria for Hazardous Liquid...

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On May 21, the Pipeline and Hazardous Materials Safety Administration (PHMSA) submitted an advance notice of proposed rulemaking (ANPRM) to the Office of the Federal Register (publisher of the Federal Register) seeking public...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Shipping...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an April 8th Interpretive Letter a question regarding the Hazardous Materials Regulations (“HMR”) applicable to the use of United...more

Jones Day

PHMSA Issues Proposed Rule Seeking to Impose Enhanced Safety and Operational Requirements on Carbon Dioxide Pipelines

Jones Day on

On January 10, 2025, the Pipeline and Hazardous Materials Safety Administration ("PHMSA") issued a proposed rule setting forth revisions to the federal Pipeline Safety Regulations ("PSR") (49 C.F.R. Parts 190-99) to include...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Carbon...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 3rd Interpretive Letter the applicability of the federal Hazardous Materials Regulations (“HMR”) to a device designed...more

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