Master Meter Operator Resource Center
As a property manager, HOA board member, or owner of a multi-unit gas system, you play a vital role in Hawaiʻi’s energy infrastructure. Under federal law (49 CFR Part 191 & 192), entities that distribute gas to multiple customers or multiple buildings are defined as "Operators."
While Hawaiʻi Gas maintains and repairs its infrastructure up until the final Hawaiʻi Gas billable meter, the Master Meter Operator (MMO) is responsible for the safety, maintenance, and federal compliance of all downstream piping from the Hawaiʻi Gas meter.
Am I a Master Meter Operator (MMO)?
Not every property with a gas meter is a Master Meter System. The determination of whether your system falls under federal safety jurisdiction is based on how the gas is distributed and who the end consumers are.
- Federal Reference: For specific criteria regarding system size and applicability, please refer to 49 CFR §191.3 (Definitions) and the scope of 49 CFR §192.1.
- The Rule of Thumb: If your private system distributes gas to multiple separate tenants, residents, or commercial entities, federal safety standards likely apply. Generally speaking, you are considered a Master Meter Operator if your system distributes gas to an "ultimate consumer" (such as a tenant, resident, or concessionaire) who pays for that gas:
- Directly: via a separate gas bill or sub-meter.
- Indirectly: through other means such as rent, HOA dues, or lease agreements.
Note: If a property uses gas solely for its own central heating or hot water (where the entity itself is the consumer), it generally does not meet the MMO definition. However, providing gas to separate units or tenants may trigger federal oversight. If you are unsure of your status, we recommend consulting with a qualified pipeline safety professional to review your specific piping configuration and customer count.
MMO Compliance Roadmap
To help you navigate these requirements, we recommend reviewing the official PHMSA guides for small operators:
- Small Natural Gas Operator Guide (PDF) – A plain language manual covering essential safety requirements for natural gas systems.
- Small Liquid Propane Gas Operator Guide (PDF) – A plain language manual covering essential safety requirements for liquid propane gas systems.
- DIMP Guidance for Small Operators (PDF) – Detailed instructions on managing system integrity.
Core Responsibilities for MMOs
To meet federal safety standards, every Master Meter Operator must ensure the following are in place:
- Operations & Maintenance (O&M) Procedures: A written manual outlining how you operate your specific gas system safely.
- Emergency Response Plan: Clear procedures for notifying residents and Hawaiʻi Gas in the event of an emergency or odor of gas.
- Operator Qualification (OQ): Any person (employee or contractor) performing work on your jurisdictional gas piping must be "Operator Qualified" to ensure the work meets federal safety standards.
- Leakage Surveys & Patrolling: Periodic testing of all buried customer-owned piping using specialized gas detection equipment and patrolling for signs of leaks or hazardous conditions.
- Cathodic Protection Monitoring (§192.465): Buried metallic pipelines must be tested annually by a qualified technician to prevent corrosion. Aboveground metallic pipelines must be inspected every 3 years by a qualified technician to prevent corrosion.
- State One-Call System: As an operator of a distribution pipeline system, you should be a member of the state 811 One-Call system to ensure third parties do not damage your lines during excavation.
Frequently Asked Questions (FAQs)
Does this apply if I don't charge my tenants for gas?
Yes. Even if the gas reaches the consumer via rent or other fees, PHMSA classifies you as an operator.
Who can perform these checks
You must use qualified contractors who understand Part 192 requirements.
What happens if I don't comply?
Federal and state regulators may issue fines. Additionally, Hawaiʻi Gas may be required to interrupt service if a downstream system is deemed unsafe or lacks required safety documentation.
