If you run a small city gas system, you may have heard that PHMSA put out something new on distribution integrity management this summer. It did, but it's worth being clear about what kind of document it is before anybody starts rewriting a plan.
What came out
On July 13, 2026, PHMSA published Advisory Bulletin ADB-2026-06, "Guidance for Enhancing the Effectiveness of Distribution Integrity Management Programs," in the Federal Register (document 2026-14071, docket PHMSA-2026-2443). It grew out of National Transportation Safety Board recommendations after a February 23, 2018 natural gas distribution incident on an Atmos Energy system in Dallas, and later incidents in Jackson, Mississippi.
What it is not
It is not a new rule. PHMSA says in the bulletin that it "does not have the force and effect of law" and is not meant to bind operators. There is no effective date and no comment period. What it does is remind operators of the DIMP requirements that already sit in 49 CFR Part 192, Subpart P, and tell you where PHMSA thinks programs fall short.
The seven elements your written plan already needs
Section 192.1007 lists them:
Knowledge — understand your system from the information you reasonably have.
Identify threats — corrosion (including atmospheric), natural forces, excavation damage, other outside force damage, material or welds, equipment failure, incorrect operations, and other issues.
Evaluate and rank risk.
Identify and carry out measures to reduce risk — and those measures must include an effective leak management program, unless every leak is repaired when it's found.
Measure performance, monitor results, and evaluate effectiveness.
Periodic evaluation and improvement — including a complete program re-evaluation at least every five years.
Report results — four measures every year: hazardous leaks eliminated or repaired, excavation damages, excavation tickets, and total leaks eliminated or repaired by cause.
What PHMSA emphasized
The bulletin asks operators to look harder at a few things:
Pipe age and older materials. Risk reviews should account for time-dependent factors like how legacy materials perform.
Threats that act together. Weather, soil type and mechanical damage can raise both the chance of a failure and how bad it is when they combine. Your evaluation should be detailed enough to see where that can happen.
A leak program that actually works, not one that exists on paper.
How often you re-evaluate. The cycle should be frequent enough to pick up what has changed on your system.
Records. Keep records showing compliance for at least 10 years.
The right risk model. PHMSA encourages operators to consider probabilistic models, and it also says qualitative and relative index models “can be effective and well-suited for smaller, less complex distribution networks.”
That last point matters for small systems. Nobody is telling a town with a few miles of main that it needs the same model a large utility runs.
A practical next step
Pull out your written plan and walk it against the seven headings above. Check three things: when your last complete re-evaluation happened, whether your leak management program is described the way you really run it, and whether your records go back far enough. That review may help you find gaps before an inspector does. It doesn't guarantee anything, and it isn't a substitute for your own regulator's reading.
If you want a second set of eyes on a plan, that’s the kind of work Z3 Collective does.
This post is general information, not legal advice. Check how these rules apply to your system with your state pipeline safety regulator.
Sources:
Federal Register 2026-14071: https://www.federalregister.gov/documents/full_text/html/2026/07/13/2026-14071.html
49 CFR 192.1007 (eCFR, current as of 10/15/2026): https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-D/part-192/subpart-P/section-192.1007