Comment from American Society for Nondestructive Testing

Executive Summary: ASNT strongly supports PHMSA’s proposal to remove outdated restrictions on nondestructive testing-based welder qualification and urges prompt finalization of the rule. 22 June 2026 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) RE: Pipeline Safety: Eliminating Limitations on Welders and Welding Operators at Gas Compressor Stations (Docket No. PHMSA-2026-1552) Dear Sir or Madam, On behalf of the American Society for Nondestructive Testing (ASNT), I appreciate the opportunity to provide comments on PHMSA’s Notice of Proposed Rulemaking (NPRM) to eliminate limitations on welders and welding operators qualified by nondestructive testing (NDT) from welding on compressor station pipe and components. ASNT represents a global community of nondestructive testing professionals who ensure the safety, reliability, and integrity of critical infrastructure, including pipelines, energy systems, aerospace components, and advanced manufacturing. Nondestructive testing is a foundational safety practice used to evaluate materials, components, and systems without causing damage, making it essential to the safe operation of energy transportation and distribution systems. As the world’s largest technical society for NDT professionals, ASNT develops industry standards, supports the qualification and certification of NDT personnel, and advances the application of inspection technologies across regulated and safety-critical industries. Through its standards, certification programs, and technical expertise, ASNT plays a central role in ensuring that inspection and qualification practices remain aligned with technological advancements and evolving safety requirements. ASNT strongly supports this proposal and urges PHMSA to finalize the rule as written. The existing restriction in 49 CFR 192.229(a) is outdated and no longer reflects the state of modern inspection technology, industry standards, or best practices. Overall Support for the Proposed Rule: ASNT strongly supports PHMSA’s proposal to remove the long-standing restriction that prohibits welders qualified through nondestructive testing from performing welding on compressor station pipe and components. This limitation, unchanged since 1970, no longer reflects modern engineering capabilities or inspection technologies. Recognition of Advances in NDT Technology: Over the past five decades, nondestructive testing technologies have advanced significantly, including digital radiography, phased-array ultrasonics, and time-of-flight diffraction. These methods provide highly reliable, repeatable, and accurate assessments of weld integrity. Alignment with Industry Standards and Best Technical Practices: ASNT’s position is aligned with that of the American Welding Society (AWS), which has stated that welders or welding operators qualified through nondestructive testing methods are as qualified as those qualified through destructive testing. Moreover, certain NDT methods, particularly radiographic examination, provide enhanced assurance by creating a permanent record of the qualification weld. This allows for independent review, traceability, and long-term verification of weld quality. In many cases, this represents a more robust and transparent approach than destructive testing. Safety and Regulatory Alignment: ASNT agrees with PHMSA’s determination that the proposed rule will not adversely affect safety. Existing standards already ensure weld quality through performance-based qualification methods. Removing this restriction preserves safety while modernizing regulatory requirements. Reducing Regulatory Burden and Increasing Efficiency: The current rule creates unnecessary inefficiencies and inconsistencies. Eliminating this restriction will increase flexibility, reduce redundant requirements, and better align regulations with industry practice. Workforce and Industry Impacts: Recognizing NDT qualification pathways strengthens the role of modern inspection technologies and supports workforce development in critical infrastructure sectors. Recommendation: ASNT strongly recommends that PHMSA finalize the proposed rule without delay. This action will modernize pipeline safety regulations, support innovation, and align federal policy with current industry practice and technological capability. Conclusion: This proposed rule appropriately reflects decades of technological advancement and aligns federal regulation with current engineering and inspection practices. It also reflects consensus across leading organizations, including ASNT and AWS. ASNT urges prompt finalization of this rule. Sincerely, Neal J. Couture, FASAE, CAE Chief Executive Officer American Society for Nondestructive Testing (ASNT) 1201 Dublin Road, G04 Columbus, OH 43215 Submitted by Garra Liming on behalf of the American Society for Nondestructive Testing (ASNT).