The Compliance HQ

Every obligation your gas system carries, on one calendar, before the inspector asks.

Operator Qualification programs, safety plans, and recordkeeping for municipal and small natural-gas distribution systems under 49 CFR Parts 191, 192 and 199 and OAC 165:20.

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Built in Oklahoma, for small systems operators

A slice of what a typical small distribution system owes in a year.
Annually
Leak survey in business districts, at intervals not exceeding 15 months; outside them, at least every 5 years
§192.723(b)
By March 15
Annual report DOT Form 7100.1-1 to PHMSA
§191.11
By March 15
Drug & alcohol MIS report, if selected
Part 199 / §199.119
Every 15 months
Cathodic protection reads on protected steel, not to exceed 15 months
§192.465
Every 15 months
Inspect and test pressure-limiting and regulating stations
§192.739
Every 15 months
Valve inspection and partial operation for emergency valves
§192.747
Per your program
OQ requalification of every person performing a covered task
§192.805(g)
Annually
Review the O&M manual and emergency plan; train personnel
§192.605, §192.615
Annually
Public awareness program effectiveness review
§192.616 / API RP 1162
Every 5 years
Full re-evaluation of the DIMP plan; annual risk review
§192.1007
Per ticket
OKIE811 locate response within the statutory window
63 O.S. §142.1 et seq.
Within 1 hour
Telephonic notice of an incident to the NRC
§191.5

What the OCC inspector will ask to see

An audit is a document request. Most findings against small systems are not about pipe; they are about a record that was not kept, a review that was not dated, or a qualification that quietly expired.

  • OQ programWritten plan, covered-task list, evaluation methods, and who is qualified for what, as of today §192.805
  • O&M manualCurrent procedures, annual review evidence, and proof staff were trained on them §192.605
  • Emergency planPlan, liaison with fire and police, and the annual review §192.615
  • Public awarenessProgram, mailing records, and the effectiveness evaluation §192.616
  • Drug & alcoholAnti-drug and alcohol misuse plans, random-pool records, contractor coverage Part 199
  • DIMPWritten integrity plan, threat ranking, and the measures you said you would take Subpart P
  • Leak recordsSurvey dates, grades, repair timelines, and re-checks §192.723, OAC 165:20
  • CorrosionCP reads within the 15-month window, rectifier checks, atmospheric inspections Subpart I
  • Damage preventionLocate tickets, responses, and any excavation-damage reports §192.614
  • Annual reportForm 7100.1-1 filed and matching your own mileage and service counts §191.11

Safety programs that stay written, dated and reviewed

Most small systems have these plans somewhere. What they usually lack is the annual review, the training record, and a person whose job it is to remember.

O&M manual §192.605

Procedures matched to your system, reviewed annually, with training sign-offs tied to each revision.

Emergency plan §192.615

Gas emergency response, mutual-aid contacts, fire and police liaison, and the documented annual review and drill.

Public awareness §192.616

Baseline program under API RP 1162, mailing and outreach records, and the effectiveness evaluation on the four-year cycle.

Distribution integrity Subpart P

A DIMP plan sized to a small system: threats you actually have, ranked, with measures you can fund, and the annual and five-year reviews on the calendar.

Damage prevention §192.614

OKIE811 tickets followed up with the right person, response times recorded, and excavation damage reported the way the OCC expects.

What's coming

Two federal rules are coming for small gas systems. The clock starts the day the first one is final.

For the Distribution Rule, PHMSA has proposed 12 to 18 months after the final rule is published. That sounds like time. For a system with two people in the gas department, it isn't — and every other small operator in the state is on the same clock.

  1. Day 0
    Final rule published in the Federal Register. Effective date set.
  2. Months 1–6
    Everyone reads it. Consultants book up. Vendors quote against demand.
  3. Months 6–12
    Plans get rewritten. Records get hunted. Equipment gets ordered — and back-ordered.
  4. Months 12–18
    Compliance date. Inspectors start asking for what the rule requires.

Both rules come out of the PIPES Act of 2020. One is moving through the final stages now. The other was finalized, pulled back before publication, and is still owed under the statute.

Moving — final rule pending

The Distribution Rule

PHMSA's response to the 2018 Merrimack Valley overpressurization. The advisory committee worked through it in May 2026; a final rule is the next step.

What it asks of a distribution operator:

  • Records for regulator stations and overpressure-protection equipment — attributes documented and available, not "somewhere in a truck."
  • As proposed in 2023, updated distribution integrity management (DIMP) content, with PHMSA naming the threats it expects evaluated: cast iron and other piping with known issues, overpressurization of low-pressure systems, and extreme weather and other geohazards — including the effect of age on each.
  • Procedures for overpressure protection, construction oversight, and emergency-response notification.
  • Reporting changes that follow the new requirements.

Docket: Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives. Advisory bulletin ADB 26-06 on DIMP risk evaluation already issued.

Withdrawn — still mandated

Leak Detection & Repair

Cleared review in January 2025 and withdrawn before publication, consistent with the January 20, 2025 regulatory freeze memorandum. The Section 113 mandate remains, so a version of it returns. When it does, it is the largest change to day-to-day gas operations in decades.

What the withdrawn rule required:

  • Advanced leak detection equipment meeting performance standards — surveys by human senses alone no longer sufficient.
  • More frequent leak surveys for distribution (every 3 years outside business districts, and every year for leak-prone pipe, as proposed in 2023), and surveys extended to valves, meters, regulators, and tie-ins.
  • Every leak graded 1, 2 or 3, each grade with a mandatory repair clock.
  • Blowdown emission mitigation, pressure-relief device requirements, and expanded reporting.

Docket PHMSA-2021-0039. Timing of the reissued rule is unknown; the obligations are known.

What happens when a rule goes final

It's the same pattern every time — the transmission integrity rules, the valve rule, the gathering rule. The operators who wait pay more and get less.

Experts book out

There are only so many people in Oklahoma who can write a compliant OQ program or DIMP plan. Twelve months out, they're booked. Six months out, you get whoever is left.

Prices follow demand

Leak-survey equipment, contractor crews, consultant day rates — all of them are quoted against a deadline the seller can see as clearly as you can.

Records don't appear on schedule

The regulator-station records the Distribution Rule wants take field visits to rebuild. That's a season of work, not a week — and it can't be rushed in winter.

The inspector doesn't grade on a curve

A compliance date is a date. "We hired someone in month fourteen" is not a finding the OCC can write down as anything other than a finding.

Get in front of it

Nothing in either rule is a surprise. The proposed text has been public since 2023. Most of the work is the same regardless of the final wording — and it's work you should be doing anyway.

ItemStart nowWait for the final rule
Regulator-station recordsRebuilt opportunistically on routine visits over the next year. No extra trips.Dedicated field campaign under deadline, at overtime, in whatever season it lands.
DIMP planReviewed now against ADB-2026-06 (interactive threats, leak management and the 5-year re-evaluation); Distribution Rule changes are layered in when final.Rewritten from scratch against the clock alongside everything else.
Leak survey programGrading and repair timelines adopted now as practice; equipment evaluated without a deadline.Equipment ordered into a national backlog; procedures written in a hurry.
OQ covered tasksLeak-survey and detection tasks added to the program as you go.Requalification wave for every field employee at once.
CalendarEvery recurring obligation already on one calendar with an owner. New rules add lines, not a system.Building the calendar and meeting the new deadlines at the same time.

Rule summaries reflect proposed and withdrawn text as of September 2026 and are provided for orientation, not legal advice. Operators remain responsible for compliance with all applicable requirements.

How it works

  1. Compliance review

    We go through your system, your plans and your records against 49 CFR 192, 199 and OAC 165:20 and give you a written list: what's in place, what's missing, what's expired.

    You don't have to have that picture in hand before you call. Starting from an incomplete one is the normal case.

  2. Build the calendar

    Every recurring obligation your system carries goes on one calendar with its interval, its owner, and the record that proves it was done.

  3. Run it together

    You perform the work and keep the authority. We keep the calendar, chase the dates, hold the records, and get you ready when the inspector schedules.

You don't have to know your system first

Records leave with the people who kept them. Maps stop matching the ground the first time a service is replaced in a hurry. If what you can hand us is a binder, a plat and one person's memory, that is enough to begin. Working out the rest is the job, not a prerequisite for hiring us.

Onsite mapping

Where the paper and the ground disagree, we arrange a walk of the system, with your staff and, where needed, a qualified expert under contract: mains, services, valves, materials and sizes, located and written down so the map is still true after we leave. What we record belongs to you.

Experts when there is work to do

A review that only produces findings leaves you where you started. When an item needs a repair, a replacement, or a valve exercised, we bring in a qualified expert under contract and close it out — with you still the operator of record.

Papers

Papers

A compliance review now costs less than a compliance scramble later.

We'll go through your system, your plans, and your records against today's rules and the two that are coming, and hand you a written list: what's in place, what's missing, what to do first. Then we keep the calendar so you don't have to.

You stay the operator of record, and your people stay yours. We run the program and the records, and bring in qualified experts under contract when the work needs them.

Request a compliance review [email protected]