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19 updated industry standards, introduces clarifying edits to existing regulatory language, and replaces several outdated references.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:
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:
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:
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
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:
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.
Steptoe & Johnson’s Midstream attorneys can help you navigate the complex world of PHMSA regulations and are available to provide you and your team with counsel on topics such as pipeline safety, emergency response, the Occupational Safety and Health Act, and energy infrastructure.
Please contact the authors of this alert as you prepare your comments for this ANPRM or with regard to any other energy infrastructure matters.
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