Extra Extra! Special edition! IA Question-sets changes summarized and PHMSA Advisory Bulletin ADB-2026-01, explained. Do not miss the Tips and Tricks section.
The weather forecast says hunker down. The compliance forecast says pay attention. While the storm rolls in outside, this is a good moment to slow things down and catch up on the updates that matter.
Consider this a special edition, read all about it moment. Evergreen:AIR™ pulled together the latest PHMSA developments so you can stay informed, warm, and inspection ready.
Inside this issue:
IA Question-Sets What's Changed. A clear breakdown of what changed, what moved, and what to pay attention to in the latest PHMSA Integrated Audit Question-sets redlines.
PHMSA Advisory Bulletin ADB-2026-01. A plain-English look at the bulletin, why PHMSA issued it, and what it signals for operators.
Breathe in that fresh Evergreen:AIR™ – Your Compliance Compass
James
What's Changed PHMSA IA Question-sets
Earlier this month PHMSA issued the annual update to the IA question sets. The "what's changed" files, as well as the updated Excel formatted versions are available on the Evergreen:AIR™ Timeline!
We've developed a great system for processing these changes, but PHMSA can throw us a curveball on occasion, and did so this year. The Gas Distribution Category and Subcategory fields were completely restructured, and many of the other question sets had questions moved around, renumbered and nomenclature fields edited. This has not been the case in the past and a little more time was needed to provide the updated information and files you are all used to seeing!
Overall changes across the board include:
The language “Note: this question is presented in multiple places so you will see multiple instances of it on this report.” was added to many more questions
Changes for Gulf of Mexico to Gulf of America and/or GOM/GOA
Minor edits to question titles and language that do not change the question
Updates to reflect changes to IBR standards
Changes to Nomenclature fields throughout, need to be aware if tracking programs, records etc.
Section 114 language remains in GT, HL, LNG question sets, and has been removed from GD. In June of 2025 PHMSA rescinded Section 114 of the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2020 and thought these questions would no longer be included in inspections.
NTSB Recommendations Review questions were removed from GT and HL
Drug and Alcohol – No Changes
Liquified Natural Gas – No Changes
Gas Transmission -
Assessment and Repair – Repair Criteria (O&M) - Added question on Receiving Notices requiring immediate response
Design and Construction – Conversion to Service (192.14) - Two new Conversion to Service Questions, was a process developed and followed, these were moved from Maintenance and Operations – Conversion to Service
Maintenance and Operations – ROW Markers, Patrols, Leakage Survey and Monitoring - Edits to three questions on ROW markers and conditions
Screening – General Screening Questions - Added question on Special Permit Eligibility Requirements
Screening – Special Permit Screening - Added question on Flow Reversal
Time-Dependent Threats – Employee Qualifications - Added two questions for procedures and records for personnel that design, install, operate and maintain CP systems
Time-Dependent Threats – External Corrosion – Cathodic Protection and Coatings new questions and edits
Time-Dependent Threats – Internal Corrosion – Corrosive Gas and Preventive Measures, some questions moved and couple of edits
Hazardous Liquid -
Design and Construction – changes throughout, new questions, and one new section on Conversion to Service with 23 questions
Tank Design and Construction – edits to questions and naming, new section on “New Shop Fabricated" (12F or 650 App. J)
Facilities and Storage – Facilities General - Edits throughout
Maintenance and Operations - ROW Markers, Patrols, Monitoring and Analysis - Changes throughout, including numbering
Screening DC – Conversion to Service - moved around with New Breakout Tanks
Gas Distribution -
The 2026 GD question set CATEGORY and SUBCATEGORY fields were completely restructured by PHMSA. This made our usual direct comparison to show changes impossible.
The 2026 question set includes 168 new questions and 11 revised questions. A separate file showing just the changed information is available to Evergreen:AIR™ subscribers, see an example below.
The 11 revised questions, and 7 of the new questions are in the "Gas Distribution Integrity Management" 2026 Category; the remaining 161 new questions are all LPG NFPA 58 and LPG NFPA 59. The LPG designations are only included in the "NOMENCLATURE" fields, and not shown in any category or subcategory fields.
The 2026 CATEGORY fields have been changed to primarily "Procedures", "Records" and "Pipeline Field Inspection"; and the SUBCATEGORY fields either the same or at a much higher subject level than in previous question sets. The exception to this is a category for "Gas Distribution Integrity Management" with more traditional subcategories. This makes the traditional sorting and filtering by CATEGORY and SUBCATEGORY less meaningful and reduces the ability to make question set lists by topic or discipline for pipeline safety program oversight and audit preparation.
Consistent with our commitment to save pipeline safety professionals across the country the time and frustration of figuring out what's changed year over year, we developed this comparison file (see image below) so the questions can still be sorted by the traditional and more granular categories and subcategories. In most cases we included 2025 Categories and Subcategories for the 168 new questions if it was clear what they would be based on the nomenclature.
This file includes all of the data from the 2025 and 2026 question set published by PHMSA for Gas Disribution. The common field is NOMENCLATURE. This file is large and unwieldly, but will allow users to filter by the 2025 CATEGORY and SUBCAGETORY fields to provide subject matter experts and others in your organization with topic specific question sets. As the file also includes the 2026 data, it can be used during agency audits to track by the categories and subcategories agency staff will be using.
Again subscribers can access these files in the Timeline links for easier access in the future.
PHMSA issued Advisory Bulletin ADB-2026-01 to remind gas distribution operators that elevated temperature exposure is a real integrity threat for certain plastic pipe and components under DIMP. The bulletin is tied to the March 24, 2023 West Reading, PA explosion and fire, where a retired 1982 Aldyl A service tee with a Delrin insert leaked gas that migrated into a building and ignited.
Why this matters: • The consequences are severe. Seven fatalities, 10 injuries, and a destroyed building in this case.
• Small temperature increases can sharply accelerate slow crack growth in susceptible plastics, and can accelerate degradation of Delrin inserts.
• Operators may not know where heat sources exist near plastic assets, especially unmarked underground utilities. If you do not identify the threat, you will not rank it, and you will not mitigate it.
• PHMSA is pushing for practical actions: inventory susceptible plastic assets in heat risk areas, evaluate and rank risk, and implement mitigations like leak management and targeted replacement or remediation.
Conclusion: If you have any Aldyl A assets or plastic components like Delrin insert tees in your system, elevated temperature exposure belongs on your threat list and in your risk ranking.
This bulletin is a reminder that “unknown heat sources” like nearby steam lines can turn old plastic into a failure mechanism faster than your program assumptions expect.
Take the practical steps PHMSA lays out, inventory, gather missing data over time, evaluate risk, then mitigate with leak management and targeted replacement or remediation.
You'll find hidden gems beneath every code section when you browse regulations in Evergreen:AIR™, don’t stop at the Code text, the real power lies just below it.
Each section comes withrelated resources that bring the regulation to life. For example, under §195.438 – Smoking or open flames, you’ll find:
2 Related Inspection Questions
0 Related Interpretations
19 Related Enforcement Actions
1 Related Enforcement Guidance
0 Related Advisory Bulletins
0 Related FAQ Items
These links instantly connect you to the inspection questions, enforcement actions, and related guidance behind each rule, no digging required. The screenshot below shows these resources related to 195.438 highlighted in orange, right where you’ll find them beneath each Code section.
And if you’re browsing Parts 191 or 192, you’ll also see GPTC Guidance linked to each section for added clarity.
So next time you open a regulation, scroll just a little further, your next compliance answer might already be waiting for you.
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