PHMSA Part 192 vs Part 195: Which Applies?
Every PHMSA obligation an operator reads eventually points back to either Part 192 or Part 195, and getting the wrong one means reading the wrong rulebook. This page compares the two parts of 49 CFR that carry the pipeline safety regulations, explains what each covers, and gives the practical test for deciding which part governs a given pipeline. It is written for the engineer or compliance owner who needs to know which rulebook their line sits in before reading any specific requirement.
Part 192 vs Part 195 in one line: 49 CFR Part 192 governs the transportation of natural and other gas by pipeline, while 49 CFR Part 195 governs the transportation of hazardous liquids such as crude oil and refined products by pipeline. Which part applies is decided by what the pipeline transports: gas lines fall under 192, liquid lines under 195. Both sit within PHMSA's pipeline safety rules and share a similar structure, but their requirements are tailored to the different behavior of gas and liquid.
What Each Part Covers
Part 192 is the rulebook for gas pipelines - transmission, distribution, and regulated gathering lines carrying natural gas and other gases. It sets minimum safety standards for design, materials, welding, corrosion control, pressure limits, testing, operation, and maintenance of gas systems, reflecting the way gas behaves: compressible, buoyant when released, and hazardous mainly through fire, explosion, and asphyxiation.
Part 195 is the rulebook for hazardous liquid pipelines - crude oil, refined petroleum products, and other regulated liquids. It sets the parallel set of safety standards for liquid systems, tailored to how liquid releases behave: a spill that spreads and persists, contaminating soil and water, in addition to fire risk. The environmental consequence of a liquid release shapes many of Part 195's requirements around leak detection and release response.
The two parts share a common architecture because they descend from the same statutory pipeline safety mandate, which is why an operator moving between them finds familiar concepts - maximum allowable operating pressure, integrity management, control room management - appearing in both. The concept of the maximum operating pressure limit, for instance, is covered in the explainer on MAOP, and the agency behind both parts in the explainer on PHMSA.
How to Tell Which Part Governs a Pipeline
The primary test is the product: what does the pipeline transport? If it moves gas, look to Part 192; if it moves a regulated hazardous liquid, look to Part 195. This is usually unambiguous for a given line, but a facility with both gas and liquid pipelines is subject to both parts across its different systems, which is why operators of mixed systems maintain compliance under each.
Beyond the product, applicability also depends on whether the pipeline meets the regulatory thresholds that bring it into PHMSA's scope at all. Purely upstream, within-facility production piping generally falls outside both parts and is handled by state oil and gas regulators instead. The line between regulated transportation pipeline and unregulated facility piping is a determination operators have to make, and recent rulemaking has moved that line for gas gathering, discussed in the explainer on the gas gathering rule expansion.
For an operator, the practical workflow is: confirm the pipeline is a regulated transportation pipeline, identify the product to pick the part, then read that part's applicability and requirements. Getting this order right prevents the wasted effort of studying Part 195 leak-detection requirements for a gas line or Part 192 gas provisions for a crude line. Both parts also carry the parallel control room management sections described in the explainer on the control room management rule.
Frequently Asked Questions
Does Part 192 or Part 195 cover crude oil pipelines?
Part 195. Part 195 governs the transportation of hazardous liquids by pipeline, including crude oil and refined petroleum products, while Part 192 governs gas pipelines. The deciding factor is the product the pipeline transports: liquid to 195, gas to 192. A crude oil gathering or transmission line that meets PHMSA's regulatory thresholds is therefore read under Part 195, whose requirements are shaped by the way a liquid release spreads and persists in the environment rather than dispersing like a gas release.
Can one operator be subject to both Part 192 and Part 195?
Yes. An operator that runs both gas pipelines and hazardous liquid pipelines is subject to Part 192 for its gas systems and Part 195 for its liquid systems, maintaining compliance under each part for the applicable lines. The two parts share a common architecture and many parallel concepts, such as maximum allowable operating pressure and control room management, so the programs overlap in structure even though the detailed requirements are tailored to gas versus liquid behavior. Mixed-system operators commonly run coordinated programs that satisfy both.
Is all pipe on an oil and gas site regulated by PHMSA?
No. PHMSA's Parts 192 and 195 apply to regulated transportation pipelines that meet its thresholds, not to all piping. Purely upstream, within-facility production piping generally falls outside both parts and is regulated by state oil and gas agencies instead. The boundary between regulated transportation pipeline and unregulated facility piping is a determination the operator has to make, and it has shifted for gas gathering through recent rulemaking that pulled more previously unregulated rural lines into Part 192 reporting and safety requirements.
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