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Clarification on Mounting Pad Requirements
PHMSA has issued a memo clarifying the requirements for attaching structural members and appurtenances in 178.337-3(g) and 178.345-3(f)(3). As I read it, structural members do not require pads. Appurtenances do. Whether an item is structural or an appurtenance might still be in a gray area. View the official version here.