In this episode of the Pipeline Technology Podcast, host Russel Treat speaks with Colin Frazier and Laurie Knape from the American Petroleum Institute (API) about pipeline safety management systems (PSMS) and recent contractor guidance.

They discuss the implementation and benchmarking of PSMS within the industry, highlighting improvements and ongoing efforts to support both operators and contractors. The conversation covers the importance of standardized safety practices and the role of industry collaboration in enhancing pipeline safety.

Contractor Guidance for Pipeline Safety Show Notes, Links, and Insider Terms:

• Colin Frazier is the Senior Manager of System Programs at API. Connect with Colin on LinkedIn.
• Laurie Knape is the Program Manager for Pipeline SMS at API. Connect with Laurie on LinkedIn.
  • API (American Petroleum Institute): Since its formation in 1919 as a standards-setting organization, API has developed more than 700 standards to enhance industry operations. Today, it is the global leader in convening subject matter experts to establish, maintain, and distribute consensus standards for the oil and natural gas industry.
• API Recommended Practice 1173established the framework for operators to implement Pipeline Safety Management Systems (SMS). A significant part of this recommended practice is a training and competency aspect.
  • PipelineSMS.org is a useful resource with various safety tools that was developed by pipeline operators to help other operators enhance safety in their operation. Read the website resources or email pipelinesms@api.org with inquiries.
  • The Plan Do Check Act Cycle (Deming Method) is embedded in Pipeline SMS as a continuous quality improvement model consisting of a logical sequence of four repetitive steps for continuous improvement and learning.
• NTSB (National Transportation Safety Board) is a U.S. government agency responsible for the safe transportation through Aviation, Highway, Marine, Railroad, and Pipeline. The entity investigates incidents and accidents involving transportation and also makes recommendations for safety improvements.
• PHMSA (Pipeline and Hazardous Materials Safety Administration) ensures the safe transportation of energy and hazardous materials.
  • The CRM Rule (Control Room Management Rule as defined by 49 CFR Parts 192 and 195) introduced by PHMSA provides regulations and guidelines for control room managers to safely operate a pipeline. PHMSA’s pipeline safety regulations prescribe safety requirements for controllers, control rooms, and SCADA systems used to remotely monitor and control pipeline operations.
• KPI (key performance indicator) is a measurable value that is intended to show how well a business is adhering to its business model and strategies.
• Check out the newly published White Paper for the Pipeline SMS Contractor’s Guide here.
• OQ (The Operator Qualification Rule) refers to the 49 CFR Parts 192 and 195 requirements for pipeline operators to develop a qualification program to evaluate an individual’s ability to react to abnormal operating conditions (AOCs) that may occur while performing tasks.
• API RP 1185 aims to use the Pipeline SMS framework to build on stakeholder engagement to support more community involvement and dialogue.

Contractor Guidance for Pipeline Safety Full episode Transcript

Announcer: The “Pipeline Technology Podcast,” brought to you by “Pipeline & Gas Journal,” the decision making resource for pipeline and midstream professionals. Now, your host, Russel Treat.

Russel Treat: Welcome to the Pipeline Technology Podcast, episode 46. On this episode, our guests are Colin Frazier, director of System Programs, and Laurie Knape, program manager for Pipeline Safety Management Systems from the American Petroleum Institute. We’ll talk to Colin and Laurie about pipeline safety management systems and the recent contractor guidance.

I am sitting here with Colin Frazier and Laurie Knape from API, and we’re at the 2024 API Pipeline and Cybernetics Conference. These guys are in charge of the PSMS contractor program. I understand y’all presented a paper. Before we get going, Colin, if you’d introduce yourself, and then Laurie, if you’d introduce yourself.

Colin Frazier: Absolutely. Thanks, Russel. Hi, everyone. Colin Frazier, I’m the director of System Programs at API, which is a fancy way of saying that I manage all of API’s assessment programs, as well as do a lot of internal coordination regarding safety to make sure everyone’s on the same page.

Laurie is the program manager for the Pipeline SMS program, so in addition to the contractor program, Laurie is in charge of all of our assessment programs and what we’re doing regarding providing support to the industry. Laurie, do you want to add anything?

Laurie Knape: [laughs] Good morning, everybody. I do report to Colin. Just to not shortchange what we do, on top of doing the assessments on operators and contractors, we do a lot of development for the pipeline industry in itself, which all of it is free on the Pipeline SMS website.

Russel: There’s a ton of valuable resources on the PSMS website. I understand you guys presented a paper yesterday on the PSMS for contractors. Tell us a little bit about what was in the paper, what’d you present? We’ll start there.

Colin: Absolutely. Thanks, Russel. Our presentation was chock full of industry updates. We use these presentations to give an update on where the Pipeline SMS industry team is and the collective programmatic efforts that we’re doing across the board.

Yesterday, Laurie and I presented an update on where we are on operator assessments. We did three operator assessments in 2023, and we presented the updated benchmarking, because we publish publicly the industry average for maturity across all the PSMS elements.

Russel: I want to ask a clarifying question about that, if I might.

Colin: Absolutely.

Russel: There are the public assessments, but there’s also assessments that are done that are not public. Is that correct?

Colin: No. We don’t…

Russel: Talk to me about it. What I’m trying to drive at is, when you talk about industry benchmarking and you say you did three assessments in 2023, that’s thin.

Colin: It is thin for 2023, absolutely. Some context there. Every year, we do a benchmarking refresh on where the industry is on implementation of Pipeline SMS, and that comes from the assessments that we do. Right now, we have 17 operators in our benchmarking database. Three were done last year, but 17 is the total number that we have in the database.

Russel: They’re doing self assessments that’s going into the database that’s helping you benchmark where we are as an industry.

Colin: We send out the assessors to do the assessment.

Russel: Just for the record, I have been on the road for over a week doing this kind of stuff, and my brain is not its normal self, so I’m having a hard time. I’m trying to get some clarity, and I’m struggling. Not a reflection on you guys, a reflection on me. 17 participants, three assessments…

Colin: Last year.

Russel: …last year.

Colin: That were added to the 14 that we had previously.

Russel: Oh, OK. I got it. You had 14 that had been done previously, 3 that were done last year, so when you’re doing benchmarking, you’re looking at that entire set.

Colin: Exactly.

Russel: Now, I got it. The brain is actually working. It’s just going slow.

Colin: Exactly. What we do, Russel, is every year, we try and understand if industry is becoming more mature, or if we’re uncovering problems, and other elements are becoming less mature. I will say this year, everything went up or basically stayed the same statistically, because we only added three new operators.

However, I will say that specifically, the two lowest scoring elements, which were stakeholder engagement and competence awareness and training, both went up by more than any other element. At least, we’re seeing a positive trend toward industry improving the areas that were the lowest.

Russel: That’s interesting, too, because one of the big topics at the conference this week has been API 1185, which is a brand new standard on stakeholder engagement, and it is also, like PSMS, it’s a programmatic standard.

It’s interesting that you’re seeing that score go up at the same time that we’re getting a new standard being published.

Colin: It’s amazing how awareness works, isn’t it, Russel? 

Russel: Not only that. The fact that we have a PSMS framework, it allows us to see where we, as an industry, need to improve. That’s a great example of how API is leading that charge.

Colin: Exactly. What we really hope is that this benchmarking, what it ends up doing is pointing API and the eight sister trades that represent the Pipeline SMS industry team, it gives us the necessary data to understand where we need to provide more support in the future so that we can close those gaps, help industry mature more quickly.

Russel: It’s awesome. What else were you presenting in the paper?

Colin: Great. Laurie–who I’m going to hand the microphone to very soon–has done a ton of work to provide support for contractors in pipeline, because, as you know, the contractors are where the risk lies. They’re the ones doing the excavations. They’re the ones doing the work on the ground.

Russel: They’re the ones with operating machinery close to the metal.

Colin: Exactly. In our mind, if we programmatically want to address risk in the industry, they have to be a part of that conversation.

What we’ve done over the past couple of years is produce some guidance that is all available for free on pipelinesms.org that contractors can go and pull these tools and assess their safety programs, do a self assessment, understand where they are, specifically how they relate to the 56 identified requirements that we pulled out of RP 1173.

Russel: Are there plans to benchmark the contractors just like you’re benchmarking the operators?

Colin: Exactly. Stealing Laurie’s thunder a little bit…

Russel: Give her the microphone, would you, Colin? You’re kind of a microphone hog.

Laurie: [laughs]

Colin: Now that the tools are created, Laurie has been producing pilots for the contractors, so we’ve been doing assessment pilots for several large contractors in the US. With that, Laurie.

Laurie: Too funny. In a very basic explanation, if you think that there’s 100 operators, we know that there’s 6,000 contractors. The workforce is contractors. The pipeline industry realized that we were not doing enough to support them, which is why we came back and we downsized the 234 shit SHELLs for operators to 56 for contractors.

The industry came through and said, “These are what we think are important for contractors.” That’s what we built our assessment against. We’ve been going out and we’ve been talking with the…So far, the contractors have been very large contractors. We’ve been doing the assessments on them and providing feedback.

Russel: They have more resources…

Laurie: They do.

Russel: …to be able to apply to the problem. It’s just like in the gas utility market, the big utilities tend to be early adopters, and they have expertise and they have capacity. When you start getting to the really small operators where there’s two or three guys running the gas system, those guys need something that’s off the shelf, but it has to be built with that expertise.

Laurie: Mistakingly…

Russel: Hold on, Colin. You can have the microphone back in a minute.

Colin: [laughs]

Laurie: Mistakingly, one of the contractors that we did an assessment on is here. He came up to chat with me yesterday. I said to him, “Would you come and talk about it?” When Colin and I did our presentation, he stood up and spoke about what they learned and what they didn’t know that they didn’t know, that classic phrase.

Russel: That kind of thing is so valuable at the pipeline conference, because what ends up happening is they put that out there, and then you walk out into the hall outside of the presentation room, and for those that are interested, they can walk up and dig deep into those kinds of questions. It’s good.

Colin: The one thing I wanted to add here, too, Russel, is throughout this entire process, we haven’t been doing this in a vacuum, only talking to operators.

We’ve been working hand in hand with the Distribution Contractors Association to ensure that they are 100 percent on board with the approach and understand that we’re not there to slap them on the wrist if they’re not doing everything perfect. We’re there to provide resources and to help them get better.

Russel: That is a mindset shift. Anytime you’re putting in any kind of safety program or quality program, you really have to fight against people wanting to think it’s punitive. No, it’s not punitive, but if we don’t understand how we’re doing, how can we get better?

Laurie: One assessment that we did, and we can share this because the person, Kevin Miller from Miller Contractors, he’s been very vocal and very supportive of the program that we did. We did an assessment on that particular group, and Kevin spoke about it at the DCA conferences very glowingly. Very informative and very helpful for them.

Russel: Excellent.

Colin: We know a program like this isn’t going to get much traction unless we have full buy in from the early adopters in that audience. 

Russel: You have to not only buy in from the early adopters, you also have to buy in from the industry associations.

Colin: Exactly. I always find that it’s always better to have someone speak on your behalf peer to peer than it is for me to stand up and talk about why this program is important.

Russel: So very true. Was there anything else you talked about other than the contractors and the assessments in the paper?

Laurie: Sure. Again, the industry, the Pipeline SMS industry team came together and that they needed…We have in our API learning an 1173 overview training, but they wanted something that drilled down to field level, because that’s where the gap is.

When we go and we do our assessments in the offices in the headquarters, they’re right on point. When we get out to the field, not so much. They really wanted something.

We have been developing with a collaboration of industry to create a very short 12 minute training program that is what they selected that they felt were, out of the 10 elements, the 6 that they felt were the most important to contractors.

Colin: I would add, Russel, the problem is that oftentimes, corporations like to speak right over where the field is mentally.

Russel: That could certainly happen.

Colin: What we decided to do was to flip training on its head. We aren’t explaining what the leadership element looks like. We aren’t explaining what stakeholder engagement look like.

Russel: “This is what PSMS means to you.”

[crosstalk]

Colin: “This is how your job…”

Russel: “This is how you need to be thinking about it, and this is how your daily work is going to be impacted by PSMS.”

Colin: That’s exactly what we were trying to do. We are happy to say that as of today, that trading is live, and you can contact us or the API training team, and we can work directly with you to get you a license for that short trading to implement in your own learning management system.

That was another point [laughs] that I was very particular about. If it was held on apilearning.org, no one would take it. We’re handing the software directly to the industry.

Russel: The contractors in particular have a unique challenge, because most of them are working with multiple operators, and across those operators, there’s variation. They need a way to go back to the operator and say, “Wait a minute, you’re not following what the industry standard is.”

That actually makes them able to get better, because if all their focus is each operator is doing it differently, and I’ve got to get approved by each operator to do it differently, I don’t want to spend my resources that way. I want to say, “No, this is the way we do it, and this is how it relates to your program.”

Laurie: That’s the benefit of the offerings that API has, is that we give that solid foundation. No matter what your scope of work is, no matter where in the country you work, we give that same solid foundation, and everybody builds on top of that, so we’re all moving in the same path.

Russel: I think, too, and this is true across our industry, is that for many things that we do, there is operator variation that is important and needs to be captured, but 80 percent ish is the same.

We spend too much time often focusing on the 20 percent that’s different and not enough time on talking about, “Are we doing a really good job on the 80 percent that’s the same?”

Colin: Russel, a quick little story about the presentation yesterday. The way I like to talk about it is, if you’ve got five binders on a shelf for every operator that you work for, and you’ve got five different safety management systems, and no one else is safer for having five different systems that you have to work with.

Russel: That’s right.

Colin: What we want to do is align everyone around a common approach so that people only have to focus on the differences.

Russel: I have one safety program, and I have an addendum for every operator.

Laurie: Correct.

Russel: Then, when I put the team together to go do a project for that particular operator, in my orientation, I’m focusing on the addendum.

Colin: That’s it.

Russel: It’s a whole lot easier to know, “For this guy, this is different,” than to know, “This is what we do for this guy, and this is what we do for this guy.” It’s just a different way of structuring and framing the information.

What was the kind of questions you were being asked? What kind of conversation occurred as you were going through this?

Colin: It’s really interesting, because I think this is one of the first times the contractors were actually brought in in a collaborative way to try and build something together.

Us even acknowledging that they were going through these problems of having these disparaging requirements between their different operators was something that they were excited to be able to tell us and come along for the ride as we try and build something that’s meant for them. [laughs]

Russel: “My goodness, you understand my pain?”

[laughter]

Colin: Exactly. It’s been wonderful. As Laurie mentioned, Kevin Miller has been the best advocate for what we’re trying to do with the contractors.

Russel: Across industry, not just operators, but across industry, operators, contractors, vendors, we are all committed to pipeline safety. We’re all trying to get better. There’s a lot of conversation that happens here about new technology and new approaches. Operators have skepticism, as they should.

Operators make their decisions slowly. They need to, because they’ve got to manage risk. By the same token, everybody’s here to learn what’s new and figure out, how can I get better?

Colin: Exactly. One thing I wanted to point out, Russel, is I think this contractor program, in addition to helping the contractors, should be able to help the operators as well. Right now, is that ISN green checkmark really helping you understand what your contractor is doing from a safety perspective?

What we’re trying to do is outline a more qualitative approach so that operators can have more programmatic discussions on safety with the contractors.

Russel: When you start getting into that conversation, the level of complexity raises, because there’s a whole another conversation about OQ, or operator qualification. What I would say is we got to get there, but we got to get this top level framework complete.

I’m going to ask you a question. Colin knows that when I’m on the podcast, I almost always ask a question that’s not anticipated. Here’s the one that…Now, he’s handing off the microphone.

[laughter]

Russel: That’s nicely played. Sorry, Laurie. Here’s the question. What about vendors? Should vendors have a program for PSMS?

Laurie: Service providers?

Russel: I’m talking about people that are providing…Maybe not service providers. Let’s talk. Let me build a little context around the question.

When you talk about contractors, you’re really talking about guys that are running digs, laying pipe, that sort of thing, but you have guys that are doing ILIs. You have guys like us that are building software tools. You have folks that are manufacturing valves. Should they have their own set of SHELLs related to PSMS?

Colin: Great question, Russel. What we’ve done…

Russel: By the way, the answer is yes, but go ahead.

Colin: I figured. Leading the witness.

[laughter]

Russel: I just want to make sure you didn’t get it wrong, Colin. [laughs]

Colin: Totally understand. It’s a really interesting conversation. What we actually did, though, when we talk about contractors and service providers, we think the contractor guide can be applicable to everyone, not just those touching the process.

Russel: To the man behind the camera, we’ve got Greg Dunn back here. Greg helps us with the podcast and all this stuff. Just a note to self, we need to read those 54 SHELLs and have our own little internal conversation. We need to be ahead of the curve here.

Colin: As part of the assessments, what we’re doing is our assessors actually go through with the contractor service provider and do a scope analysis on which of the 56 are important for their specific business function.

Russel: I get it. The thing that would be interesting is to look at it…When you go from the guys that are running construction and you go to the guys that are doing ILI in the field, I could see where there’s a lot of similarity, particularly guys that are doing hot tap, that sort of thing.

When you go from that to people like us that are offering software, or people that are doing SCADA systems, or people that are doing leak detection software, you look at these other domains that are critical to the operation and critical to safety, I’m wondering what SHELLs are missing. That, to me, is a bigger question.

Colin: That’s a very good question. I know the 56 is where industry landed at this point in time. I don’t foresee that number remaining static or those being the same SHELL statements that are present five years from now. I think this is the start, because 24 of those 56 are based on leadership. We all know safety starts at the top. We’re really trying…

Russel: That’s the right foundation. I think the future is we’re going to start driving it down, and then we’re going to start understanding departmental or functional requirements for each department. Then it’s going to continue to evolve.

If you look at the aircraft industry and you look at what they’ve done over their 30 plus year history, very, very similar journey. In the airline industry, everybody knows what the SHELL statements are around every aspect of aviation, all the way to the guy that’s flying a plane.

Listen, I want to wrap this up and…Go ahead.

[crosstalk]

Laurie: …you said. Let me add real quick before you wrap up, with those 56 SHELL statements with the contractors, because it is a new offering, we are very clear when we do these assessments that we want their feedback. Are they getting out of it what they need? Are we asking the right ones? This is what we thought as an industry team.

Russel: See, that’s a safety frame, right?

Laurie: Right.

Russel: We built this, but is it right? We don’t know. It’s what we came up with, but does it need to be modified?

Laurie: Correct.

Russel: That’s a safety frame. There’s no presumption that this is the best or the end state or anything like that.

Laurie: We are suggesting that people use the tool that we’ve created that’s on the Pipeline SMS website as part of vetting their contractors, whether you’re a contractor to a sub or whether you’re an operator to a contractor, because we do ask things that are relevant just to 1173.

We’re not asking, do you have a fire protection program? Do you have a fall protection program? We’re not asking that high level safety. We’re asking things that are specific to the operations.

Russel: That’s slips, trips, and falls. That’s personal safety…

[crosstalk]

Laurie: Exactly.

Russel: …PSMS is processing.

Laurie: All of these are free, which we’re very happy about, because we love to give things back.

Russel: They’re not free. We all play dues.

Colin: No…

[crosstalk]

Laurie: [laughs] We all pay dues.

Colin: They’re all free, even to non members. [laughs]

Laurie: They’re all free. There you go. We encourage people to use them.

Russel: OK, fine, it’s free.

[laughter]

Russel: I’m funning, of course.

Colin: API is not in the business of making money off safety.

Russel: I’ll acknowledge that. I get it. I’m just funning. We’re having a great time here at the API Pipeline Conference. This is the 2024. For those of you that are listening, you should put 2025 on your calendar. Do you know the dates for 2025 off the top of your head? I don’t have my glasses on. I can’t read that.

Colin: I don’t know the exact dates, but it’s in Austin.

Russel: April 27th through the 30th in Austin, Texas. Be there, be weird. That’s the city motto for Austin.

Colin: Keep Austin weird.

Russel: Keep Austin weird. That won’t help if I go.

[laughter]

[background music]

Russel: Anyways, look, thank you guys so much. Really educational. Thank you for helping me get square about how the assessment and benchmarking process work.

Colin: No worries, Russel. Happy to be here with you.

Russel: See you in Austin in ’25.

I hope you enjoyed this month’s episode of the Pipeline Technology Podcast and our conversation with Colin and Laurie. If you’d like to support this podcast, best way to do that is to leave us a review, and you can do that on Apple Podcasts, Google Play, or wherever you happen to listen.

You can find instructions at pipelinepodcastnetwork.com. If there’s a Pipeline & Gas Journal article where you’d like to hear more from the author, please let us know on the Contact Us page at pipelinepodcastnetwork.com, or reach out to me on LinkedIn. Thanks for listening. I’ll talk to you next month.

[music]

Transcription by CastingWords