This week’s Pipeliners Podcast episode features returning guest John Erickson of the American Public Gas Association (APGA) discussing the revisions to API Recommended Practice 1162 and the impact on public awareness.
In this episode, you will learn about the importance of public awareness when dealing with pipeline leaks. You will also learn about how technology has affected the forms of communication used to update the public and how technology also contributed to the updates made to the API RP 1162 rule.
Public Awareness & New API 1162: Show Notes, Links, and Insider Terms
- John Erickson is adviser emeritus with the American Public Gas Association. He is president of Safety and Compliance Evaluation and COO for the APGA Security and Integrity Foundation (SIF). Connect with John on LinkedIn.
- American Public Gas Association (APGA) is the national association for municipal gas utilities in the United States.
- API (American Petroleum Institute) is a national trade association that represents all aspects of America’s oil and natural gas industry.
- RP 1162 is an industry consensus standard that provides guidance and recommendations to pipeline operators for the development and implementation of enhanced public awareness programs.
- The Public Awareness Rule is a set of PHMSA pipeline safety regulations that require pipeline operators to conduct continuing public awareness programs to provide pipeline safety information to stakeholder audiences.
- PHSMA (Pipeline and Hazardous Materials Safety Administration) ensures the safe transportation of energy and hazardous materials.
- APGA GOAL (Gas Overall Awareness Level) measures safety-awareness effectiveness as required by PHMSA Regulations 49 CFR 192.616 and API Recommended Practice RP 1162. [Read more about the GOAL program]
- Pipeline SMS (Pipeline Safety Management Systems) or PSMS is an industry-wide focus to improve pipeline safety, driving toward zero incidents.
- Deming Method is a continuous quality improvement model consisting out of a logical sequence of four repetitive steps for continuous improvement and learning: Plan, Do, Check (Study), and Act. The Deming Method is integral in Pipeline SMS, as outlined in API RP 1173.
- Angie Kolar is a chair on the Pipeline SMS Working Group and recently provided an update on Pipeline SMS. [Download the Presentation]
- The New London, Texas Incident in March 1937 was the result of a natural gas leak in the London School. According to reports, gas had been leaking from a residue line tap and built up inside the enclosed crawlspace that ran the entire length of the building’s facade. A spark then ignited the gas, causing the building to explode, injuring or killing hundreds of students and teachers. This led to the emergence of the Texas state legislation requiring the odorization of gas distribution lines.
- The Mounds View, Minnesota incident occurred on July 8, 1986 when a petroleum pipeline ruptured due to an electrical resistance welded (ERW) seam failure. 200 people had to evacuate their homes and two people, a mother and her young daughter, were killed in the incident.
- The Bellingham Pipeline Incident (Olympic Pipeline explosion) occurred on June 10, 1999, when a gas pipeline ruptured near Whatcom Creek in Bellingham, Wash., causing deaths and injuries. Three deaths included 18-year-old Liam Wood and 10-year-olds Stephen Tsiorvas and Wade King.
- The NTSB accident report attributed the cause of the rupture and subsequent fire to a lack of employee training, a faulty SCADA system, and damaged pipeline equipment. [Read the NTSB Pipeline Accident Report]
- Larry Shelton provided his first-hand account of the incident in Episode 79 of the Pipeliners Podcast.
Public Awareness & New API 1162: Full Episode Transcript
Russel Treat: Welcome to the Pipeliners Podcast, episode 134, sponsored by Energy Worldnet, a worldwide service provider to the oil and gas industry, making the world a safer place by providing pipeline operators and contractors innovative solutions for operator qualification, safety training, content authoring, and guidance as pipelines operate in compliance with PHMSA, OSHA, and other regulatory requirements. To learn more about Energy Worldnet, visit energyworldnet.com.
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Announcer: The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. Now your host, Russel Treat.
Russel: Thanks for listening to the Pipeliners Podcast. I appreciate you taking the time. To show the appreciation, we give away a customized YETI Tumbler for one listener each episode. This week, our winner is Joshua Bremner with Phillips 66. Congratulations, Joshua, your YETI is on its way. To learn how you can win this prize pack, stick around to the end of the episode.
This week, John Erickson of the American Public Gas Association returns to talk to us about Public Awareness and the new API Recommended Practice 1162. Hey, John, welcome back to the Pipeliners Podcast.
John Erickson: Hey, glad to be here.
Russel: How you’re hanging in with the whole COVID-19 thing going on?
John: I’m keeping myself occupied by growing a beard.
[laughter]
Russel: I think that is probably thematic. I’m not going with the beard thing because I did that for about two and a half weeks. It was driving me crazy. I am only shaving about once a week. I’m in desperate need of a haircut.
John: Yeah, same here. I look like a caveman.
[laughter]
Russel: Exactly. Look, I asked you to come back on to talk about public awareness. I know you’ve got a background in that. Just to tee the conversation up, let me ask you this question, what is public awareness and why is it important?
John: Public awareness is basically educating the public about pipeline safety, and me being on the natural gas side, natural gas safety. Distribution utilities, actually, maybe their number one concern is educating customers and non-customers how to recognize a leak, not from a pipeline, but from inside the house and appliances.
Basically, it’s how to recognize and react to a leak. Also, the importance of calling before you dig and other unique safety messages that some operators may have, carbon monoxide safety. It’s been part of the pipeline safety regulations ever since the very first.
Russel: I have a theory — and I think it’s accurate — that every line in the pipeline safety code goes back to something that happened that required that line to be put in the pipeline safety code.
John: Yeah, I don’t know that there’s a particular accident that happened. There are some that led to the change that was made in 2005, but I think it just goes back to good business practices. That there are operators who have customers that don’t understand what gas smells like.
Once they started adding odor into gas, it just made sense to be educating customers that, if you smell this, it could be gas. Give us a call, and we’ll come out and investigate.
Russel: There are some utility type, I would say, incidents that occurred all the way back in the ’30s, before gas was odorized, that really started bringing the need for public safety around natural gas distribution to the top of public awareness, if you will.
John: Right. I think there was a school that exploded back in maybe the ’40s or ’50s [1937] there in Texas. Unodorized gas that led to the requirement or standard for odorizing. Both odorizing and the idea of public awareness were in effect long before any federal regulations on pipeline safety were in effect.
When the Fed started regulating in ’70, ’71 time period, they basically just adopted what best practices of the industry already had been for decades.
Russel: I think that’s also just an important thing to note is that the pipeline safety code didn’t come into place because there was nothing there. It was more about how existing standards were being followed across the country and establishing a minimum level.
John: Part of it, there’s a big difference, too, between local distribution companies and interstate oil and natural gas transmission operators. I think most people living in towns know that there are underground utilities in their area.
Not just gas, but electric, water, or sewer. They don’t expect a 36-inch, high-pressure transmission line or a gasoline pipeline. There were some accidents. In the ’80s, there was an accident in Mounds View, Minnesota, where a gasoline pipeline sprung a leak in a residential area.
Post-accident investigation, none of the residents said they were aware it was there. Then there were, I think, the accident in Bellingham, Washington and also a gasoline pipeline that residents nearby said they weren’t aware of.
The whole idea is that transmission operators have a much different challenge than local distribution operators, because just the people expect distribution lines in urban areas, but not transmission.
Russel: I think, too, that even the utilities, when you start talking about their distribution mains, that’s a different conversation than the feeder lines and the low-pressure lines going through the house.
John: Right.
Russel: The public wouldn’t generally know that kind of thing, unless they were educated about that.
John: That’s right.
Russel: You mentioned something changed in 2005. What changed in 2005?
John: After those accidents that happened in the ’80s and ’90s that raised the attention about public awareness, the American Petroleum Institute began developing a recommended practice for pipeline public awareness.
Ended up getting the number, the designation RP 1162. That came out, the first edition, in 2003. In 2005, the Pipeline and Hazardous Materials Safety Administration went through a rulemaking and incorporated by reference RP 1162 into the pipeline safety rules.
What had been a recommended practice, not mandatory, became regulation mandatory. RP 1162 had a lot more details about what operators should do to ensure educating the public and ensuring that the public understood the messages.
Russel: That makes perfect sense. I think I want to come back a little bit and talk about the distinction between, we’ll call it, transmission and utility. Those are really, you make an excellent point in that the public awareness need is quite different.
With the larger lines and the liquid lines, it’s more about you just want people that are close to them and to know what to do if they see something.
John: Right.
Russel: Where, with the utilities, it’s really quite a different problem, because what you want people is to call before they dig and know what to do when they smell gas. A lot of times, that’s stuff that’s going on inside their house.
John: Right. It’s ironic that the main public awareness issue for distribution companies is leaks on pipes that aren’t even theirs.
Russel: Right. [laughs] Yeah, and there’s liability there.
John: Exactly.
Russel: It’s pretty substantial.
John: I do expert witness work on the side, and it’s almost always a leak on the customer’s side of the meter. The whole issue of their public awareness, is it up to snuff? Did they make sure people know? That all comes up in the discovery.
Russel: Right. Really, the other thing I want to talk about is what is new? You mentioned that RP 1162 came out originally in 2003. Has it ever been updated since that time?
John: It was updated once around 2010, the second edition. The PHMSA never replaced the first…They never went through a rulemaking to incorporate the second edition. We’re still required to follow the first edition that came out in 2003.
Russel: I think this is a really interesting example of the speed of technology versus the speed of rulemaking.
John: Yeah.
Russel: I’m thinking about a listener listening to this conversation. If you think about what was the state of…Public awareness is largely about mass communications.
John: Right.
Russel: If you think about what was the state of mass communications in 2003 — which is over 15 years ago — and what is the state of mass communications today, that almost predates Facebook.
John: Absolutely. I was just saying that’s exactly what’s going on, that back then, the main method of getting things out was direct mail or maybe radio and TV. Now, you’re looking at Twitter, Facebook, and websites. Really, people would prefer to get their information that way.
Russel: You look at the cost of doing direct mail. That is a high-cost activity, versus the alternatives. I don’t know about most people, but for me, the junk mail never makes it past the nearest trash can in between the mailbox and the house.
John: Yeah, and actually, that’s ironically how some state inspectors have interpreted the requirement that you have to prove you sent something to an individual, especially if it’s a non-customer living near your lines.
The experts in the area, I don’t claim to be a public awareness expert, but I am on the API committee. The people that are there say, “We’d much rather use mass media, but we can’t prove that an individual got it, so we’re required to use something that is more expensive and less effective.”
Russel: There are ways to prove in some of the newer social media platforms that somebody actually looked at it.
Now, tying that to the right person and the right location, that’s a whole different thing, but it does point out very clearly how advances in technology and changes in people’s behavior radically impact the viability of a standard that’s 15 years old.
John: Right. One of the big changes that the incorporation of RP 1162 did was, prior to it, to demonstrate compliance, an operator just had to show, “Here’s the information I mailed out, and here’s the date I mailed it.”
Now, after RP 1162, they’re required to do an effectiveness assessment, where you do a statistical sample survey of people in all the various stakeholder groups and show, did they remember getting the message? Did they understand it?
A lot of it, like APGA set up a program called GOAL, Gas Overall Awareness Level, which surveyed customers and non-customers using robo calls. It’s very efficient, very cost-effective, but nowadays, myself included, if the phone rings, and I don’t recognize the number, I don’t answer it. It goes to voicemail.
We’re having to rethink how we do those kind of surveys, maybe do it through a Facebook or through the Internet somehow.
Russel: If you think about that from a standard writing’s perspective, you want to try and write the standard so that it’s independent of technology and independent of behavior. That’s virtually impossible [laughs] to do.
John: Yeah, you never know what’s going to come up next, especially how fast things are changing nowadays.
Russel: Oh, yeah, for sure.
John: You look at the differences between what the Baby Boom generation does as far as communication and the Millennials do, and it’s completely different.
Russel: That’s exactly right. The other part of that is, if you think about those people who are living at home that are 75 years old or older, a lot of those people…My mother, who — bless her heart — she wouldn’t even use a smartphone.
John: You just gave me a brilliant idea. We should do all our effectiveness assessments right now, because most people would just love to complete, have something to do, complete a 30 question survey on the phone just to kill that five minutes.
Russel: And to have some human interaction with somebody they don’t normally interact with. I think you’re probably onto something there, John.
John: There we go.
Russel: I don’t know exactly when this is going to drop, but just for those that are listening, we are in the…Well, it’s getting towards the end of April here, just to give you a little context, as we’re recording this.
That’s a whole nother conversation, talking about the speed at which things change. This whole COVID thing started early March, early to mid-March. Here we are, next to the last week in April, and man, things are changing rapidly. [laughs]
John: Yeah.
Russel: I expect by a month from now, when this actually drops, and people are listening to it, they’re going to go, “Oh, yeah, I remember way back in April when we were doing such and such.” [laughs]
John: Yeah, I would love to do a phone survey back then.
Russel: Yeah, it’d be something to keep you busy, right?
John: That’s right.
Russel: What kind of specific things have been updated in RP 1162? I know that you mentioned that you’re on that committee, and I think that the update to that recommended practice is imminent. I’m curious what kind of new things are being added.
John: The biggest change is in the area of effectiveness assessment. It was performance-oriented in the original. It just said, “Conduct a survey.” It didn’t go into a lot of detail about what has to be in it. We interpret it that we should try to get a statistical sample, a random sample, but not all operators have done that.
The revision to the effectiveness assessment part, one, they’ve come up with a list of mandatory questions that, for each of the stakeholder groups, affected public, emergency officials, public government officials, and excavators, here are the exact questions you should ask.
The benefit of that is it allows some comparison of yourself with your peers in the industry to see how you’re doing. This is one I actually commented on. It being an American Petroleum Institute working group, it’s dominated by interstate oil and natural gas operators.
They write things one way, like they refer to themselves in the questions as pipeline operators. I don’t know of a single local distribution company that refers to themselves in their public awareness as a pipeline operator.
It’s usually your local gas company or local gas utility. The working group agreed, “Okay, you can change pipeline operator to local gas company and make some minor changes.” Otherwise, the way it’s currently written, we’ll say, “You must ask these exact questions exactly the way they’re written.”
It also will require a more formal process for evaluating the results, calculating what the statistical significance is, whether there’s any statistically significant change from the prior evaluations.
Hopefully, it’ll show either a statistically significant improvement in the level of public awareness, or at least not show that it’s degrading. That’s the biggest area that I see, but there also are some more requirements for documenting the process that you’re following for doing various tasks.
Such as there’s a requirement if there are significant population of non-English speakers. You have to provide public awareness that language that they speak other than English.
The current draft would require you to have a process that you follow to determine whether there is a statistically significant number of non-English speakers that you need to communicate to in their own language.
There are a few other areas like that as well. The other thing they’ve done is reduced the number of messages. Some of the original version required that you provide messages about the roles of pipeline in the energy industry of the United States and the benefits of pipelines.
That’s a good thing you want people to know, but it’s not really a safety message, so they’ve made that optional in the new version.
Russel: Interesting. I think I want to dive into a couple things you’ve said here, because to me, I think all of the standards and recommended practices are probably going to be influenced by the idea.
That is this idea of benchmarking, normalizing data collection across multiple pipeline operators in a way that I can correlate and benchmark the industry performance versus just my individual performance.
I think we’re going to be seeing a lot more of that in a lot of areas other than just public awareness. Do you think I’m off base there, or do you see that as well?
John: No, I think that’s exactly it. Actually, the GOAL program that I mentioned has about 180 distribution systems using it. We actually provide them with not only their results but the composite results of all the other 179 operators so that they can do exactly that.
I think, in a lot of areas, the statistics are there. It’s just a matter of putting them together. I know API has talked about putting up a website on public awareness to provide additional information. One of the things that may be there would be a way to compare yourselves against your peers.
Russel: Yeah, I think that’s exactly right. The other area you’re going to begin to see a desire for this is in the areas of, particularly around pipeline integrity, and probably around cathodic protection as well.
John: Yep, very well. The other trend that we’ve seen in a lot of pipeline safety regulations is a requirement to document the process that you’re following. A pet peeve of mine, I know a lot of my peers say, “Is it important that you document the process, or that you have a process and you follow it?”
It doesn’t need to be written down in detail, but that’s something we’re going to have to live with.
Russel: Actually, John, that goes right to the next question I was going to ask you, which is around Pipeline Safety Management. You cannot do Pipeline Safety Management if you don’t have a documented process. It’s a fundamental requirement. If you go back, and you read Deming’s work, the prerequisite to do any quality improvement or any safety improvement is first a well understood and documented process.
Only with that can you do the analysis necessary to determine how to make it better.
John: Yep, although the one thing, the level of detail of those processes can vary by size. I was on the API Pipeline Safety Management System working group as well and had to make that point.
That if you’re a small utility with eight employees that all report in and out of the same building every day, your management of change policy will be a lot different than Kinder Morgan with 25,000 employees scattered all over the U.S.
Russel: Right. You’ve got to build a system that’s appropriate in its scale and complexity for the operation that you’re looking to improve.
John: Right.
Russel: The other thing is if, and…Man, way, way back in my history, I did some operations effectiveness analysis at the manufacturing level, where you take a single manufacturing line, and you break down every little bitty piece, part, and roller, and everything in that line to understand what’s going on.
Then after you’ve done that, you start talking about, “Well, what could I change to improve it?” You could do that at a higher level and maybe get some improvement, but once you get a manufacturing line up over 90 percent efficiency, getting it up to 98, that’s a whole different thing than getting it to 90.
John: That’s actually one of the challenges we’ve faced is the results of our GOAL, which, incidentally, we started our survey in 2006, even though the regulation said the first one isn’t required until 2010.
We wanted to see what our baseline is before we implement all these new requirements of RP 1162. We did the surveys back in 2006 and actually found upwards of 90 percent understanding in both customers and non-customers that natural gas had a smell, that it was flammable, and that if you thought you smelled gas, you should call.
It’s hard to really improve from when you’re starting at that level.
Russel: Again, it points out the difference between the challenge for a gas utility operating in a city, where that would be generally known and understand, versus I’m a crude oil carrier, and I’m running through smaller communities.
I just need to have people know I’m there. From there, I’m probably trying to get from some relatively low number to a better number. What you do to accomplish that’s different. It’s very interesting. It’s very interesting.
John: I was ribbing the other folks on the API working group that, when they thought about having these benchmarks up on their site, I said, “The distribution industry would love to compare ourselves with interstate oil and gas transmission, because I think we’d look really, really good.”
Russel: [laughs] At least in this domain, for sure.
John: Right, I think our challenge…I always joke that I feel sorry these interstates that go through hundreds, if not thousands, of different jurisdictions on the length of their pipeline. Most of our distribution companies, particularly the municipals, only are in one town or one county.
I joke they can go up on the roof of their office building and see from one end of their pipeline to the other.
Russel: [laughs] Right.
John: The challenges are a lot different.
Russel: That’s exactly right. It’s a point very well made. I want to wrap this up, because I know most of your career, or a big part of your career, has been working with the smaller public utilities.
I wanted to ask, once you start unpacking what public awareness is, it’s like a lot of other disciplines in pipelining. On the surface, they might seem fairly simple and straightforward, but once you actually start unpacking what you got to do, it starts getting complex really quick.
How do these small utilities address doing public awareness, and for that matter, modifying a public awareness program in order to be able to meet the changes that are coming out in a new recommended practice?
John: Most of the messages that are in the recommended practice are the same messages that they’ve been communicating for years. They still do bill stuffers. They still do going to elementary schools, doing demonstrations, and things such as that.
In some cases, it’s a lot easier. We’ve had one superintendent of a utility say, “The only difficulty I have liaisoning with the fire department is I’m also the chief of the volunteer fire department. I have to talk to myself.”
They’re government-owned, so the mayor and the city council are well aware that they have a gas distribution system. Generally, because the mayor’s always asking, “Why are these expenses so high and the revenues so low?”
Russel: That Friday night at the high school football game, too. That’s where they have that conversation.
John: Right. The big challenge was this idea of having to do effectiveness assessment, because they’re generally not experts on statistical sampling and may not have the resources to hire someone to come in and do it.
Then the challenge is to get a 95 percent confidence level, you need to get about 400 completed surveys. If you’ve only got 1,000 customers, that’s a 40 percent response rate. The experts tell us that the expected response rate is less than five percent.
They just can’t get enough responses to have something that they can hang their hat on and say, “This is statistically significant at a 90 percent confidence level.” The new RP is addressing that, that basically will say, “If you contact every one of your customers and only get five percent response, that’s good enough. You’ve made your best effort.”
We’re happy with that part of the RP if it makes it through balloting and the final comments.
Russel: Excellent. Great. Well, John, this has been a great conversation. Is there any summary commentary you’d like to put on this whole topic of public awareness and new…Oh, I should ask this question.
When do you think the new RP 1162 will be complete? I know that is gross speculation anytime you ask that question, but what’s your best guess?
John: My best guess would be sometime in July of 2020. All of the comments are in. That’s what I’m killing time with, going through 1,600 comments that came in on the final draft. There’s going to be a virtual meeting on the first week of May to go over all the comments with the working group.
If we resolve them all, it would only take a few weeks, I believe, for API to be able to get it out. Then the big question is, it’s still not the rule of the land until PHMSA goes through a rulemaking and replaces version one with version three. That could take a year or two.
PHMSA’s been real active in the version three working group, and they’ve said they intend to go through that rulemaking, unless something incredibly unusual happens in the review that makes it not palatable to them. I think probably around 2022, we’ll see this revised version become a regulation.
Russel: Yeah, that makes sense. The other thing I think PHMSA is doing — and they’ve made multiple presentations on this topic in different forms — but they’re trying to take these, I’m going to call them administrative rulemakings, where they’re trying to catch the rule out to the current version of the standards and put all those together as they are easier to move through the process.
John: This one may be more complicated just because it’s such a significant change.
Russel: Yeah, that certainly makes sense. Then I come back to my other questions. Any final comment you’d like to make about just public awareness in general?
John: I think it’s important that we proved even before it became regulation, operators were already doing it. It’s important, but it’s a challenge, because as you said, trying to get people to actually pay attention to what you’re telling them and read what you’re sending them is difficult.
Russel: Excellent. Look, John, thanks for coming back on the Pipeliners Podcast. Always a pleasure to have you. Hopefully, we got you a little bit of variety in your day, and you’ll do a better job of surviving your COVID sequester.
John: Yeah, they didn’t deliver my newspaper today, so I can’t do the crossword puzzle.
Russel: [laughs] Sounds like I like your lifestyle.
John: [laughs] Being retired and living on the beach is nice.
Russel: Exactly. All right. Thanks again. We look forward to having you back.
John: Great. I look forward to it.
Russel: I hope you enjoyed this week’s episode of the “Pipeliners Podcast” and our conversation with John Erickson. Just a reminder before you go. You should register to win our customized Pipeliners Podcast YETI Tumbler. Simply visit pipelinepodcastnetwork.com/win to enter yourself in the draw.
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