WP-G1 · Version 1.0 · As of September 2026

Gas · Municipal gas superintendents, city managers and small distribution operators

The calendar you already owe, and the rules coming

Most findings against small gas systems are records findings, not pipe findings. This paper sets out the recurring obligations a small distribution system already carries, the federal rules now in motion, and why starting the records work before a rule is final costs less than starting it after.

The year you already owe

A small gas distribution system owes the same core tasks every year, plus a few that run on three- and five-year cycles. We keep that calendar for you and hold the dated record that shows each task was done. Under 49 CFR 192, the operations and maintenance (O&M) manual is reviewed at intervals not exceeding 15 months, but at least once each calendar year. The same interval applies to cathodic protection tests, inspections of pressure regulating and relief stations, valve checks, and leak surveys in business districts. Leak surveys outside business districts are due at least once every 5 calendar years, at intervals not exceeding 63 months. Atmospheric corrosion checks on pipe other than service lines are due every 3 calendar years, at intervals not exceeding 39 months. The distribution integrity management program (DIMP) gets a complete re-evaluation at least every five years, and its records are kept for at least 10 years. The federal annual report is due by March 15 for the prior year; master meter systems do not file it. Some duties run on an event, not a date. An incident must be reported by phone to the National Response Center no later than one hour after confirmed discovery. From 1 July 2026 through 30 June 2027 the federal property-damage trigger for an incident is $153,600 (49 CFR 191.3), and it changes every 1 July. In Oklahoma, the OCC Pipeline Safety Department must also be told within one hour (OAC 165:20-5-11). In Indiana, the IURC must be called within one hour, and Indiana's own incident definition triggers at $50,000 of property damage (170 IAC 5-3-0.5(b)(5)).

What an inspection actually asks for

An inspector asks to see paper: the written plan, the procedure, and the dated record that shows it was followed. In a memo of 17 July 2025, PHMSA set five inspection and enforcement priorities. They are incidents and accidents, including distribution integrity management under Subpart P and incident reporting; high and moderate consequence areas; control room management and leak detection, including leak surveys, hazardous leak repair and the O&M manual; damage prevention, including the effectiveness of public awareness programs; and transactions and due diligence, including operator ID updates. The memo is internal policy, not a rule. It says state agencies with PHMSA certification are encouraged to follow it.

The rules in motion

The Distribution Rule, "Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives", was proposed on 7 September 2023. It carries out the Leonel Rondon Pipeline Safety Act, written after the 2018 Merrimack Valley overpressurization. It is still a proposal. On 28 May 2026 the Gas Pipeline Advisory Committee voted on seven topics, and each motion passed 12-0. On 4 August 2026 PHMSA said it will carefully consider the committee's report when finalizing the rule. The August 2026 DOT regulatory agenda lists the rule at the proposed-rule stage, with no final-rule date. PHMSA proposed that operators get 12 to 18 months after a final rule to comply; that figure is for this rule only. The Gas Pipeline Leak Detection and Repair rule was proposed on 18 May 2023. A final text cleared federal review in January 2025, but it was withdrawn on 21 January 2025, before publication, and PHMSA calls that text unofficial. The August 2026 agenda lists the rulemaking as "Next Action Undetermined". The statute that requires it is still in the U.S. Code.

What changes on the ground

If it is finalized as proposed, the Distribution Rule would add written procedures for responding to overpressure, a management-of-change process in the O&M manual, new pressure-control records, wider emergency-response communications, changes to DIMP, and additions to the annual report. At the advisory committee meeting PHMSA said it was considering narrowing some of these. None of it is law yet. Two smaller proposals would also move dates on the calendar: the annual report from March 15 to June 15, and a return to a 5-year atmospheric corrosion interval for replaced service-line segments. Both are proposals only. Today March 15 stands, and a service line where atmospheric corrosion was found at the last inspection is re-inspected within 3 calendar years, at intervals not exceeding 39 months. Two changes are already final. Since 3 November 2025, a deadline in PHMSA's enforcement procedures that falls on a Saturday, Sunday or federal holiday moves to the next business day (the definition of Day in 49 CFR 190.3). On 1 January 2027, updated editions of standards for plastic pipe, fittings and joining take effect, including ASTM D2513, F1055 and F2620.

Start now, or wait for the final rule

Nothing in a proposal binds until a final rule is published. But most of what the proposals ask for is written procedures and records, and those take time to build well. The duties in force today ask for the same habit: a dated record for every survey, test and review. A system that keeps those records now has less to build when a final rule lands. We keep the calendar for what you owe today, we follow the proposals that would change it, and we tell you when a proposal becomes a rule and what it will ask of you. Penalties run per violation, per day. The federal maximum under 49 CFR 190.223 is $272,926 per violation per day and $2,729,245 for a related series. The 2026 Indiana Code sets $200,000 per violation per day and $2,000,000 for a related series (IC 8-1-22.5-7(a)).

Why TheComplianceHQ

We run your compliance program as a service: the calendar, the records, the plans and the filings for your signature.
You stay the operator of record, and your people stay yours. When the work needs a credential or a field specialist, we bring in a qualified expert under contract.
We keep a dated record of each task as it is reported to us, and we record a correction as a new dated entry showing what it replaced, so the file answers the inspector's question the day it is asked.
One calendar across every system you run, so the same people, trucks and tickets are never tracked twice.

Sources

This paper is provided for orientation and is not legal advice. Operators remain responsible for compliance with all applicable federal and state requirements.