On this week’s episode of the Pipeliners Podcast, Terri Larson returns to the show to discuss the third edition of API RP 1162 and the new Public Awareness website – intended to help operators navigate key changes in the revision.
Listen to the episode now to learn more about navigating the guidance website, changes in communications practices over the last 20 years, and resources for how to implement changes in the most recent revision of 1162.
API 1162 and the New API Public Awareness Website Show Notes, Links, and Insider Terms:
- Terri Larson, APR is the owner of Larson Communications & Consulting. Connect with Terri on LinkedIn.
- Visit the Public Awareness Programs for Pipeline Operators website.
- API (American Petroleum Institute) represents all segments of America’s natural gas and oil industry. API has developed more than 700 standards to enhance operational and environmental safety, efficiency, and sustainability.
- API 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.
- API 1173 established the framework for operators to implement Pipeline Safety Management Systems. The PSMS standard includes 10 core elements. The API Energy Excellence Program followed this model to establish its 13 core elements.
- PHMSA (Pipeline and Hazardous Materials Safety Administration) is the federal agency within USDOT responsible for providing pipeline safety oversight through regulatory rulemaking, NTSB recommendations, and other important functions to protect people and the environment through the safe transportation of energy and other hazardous materials.
- SWOT Report (strengths, weaknesses, opportunities, threats) examines the brand by its strengths, weaknesses, opportunities, and threats.
- The PDCA (Plan-Do-Check-Act Cycle) is embedded in Pipeline SMS (API RP 1173) as a continuous quality improvement model consisting of a logical sequence of four repetitive steps for continuous improvement and learning.
API 1162 and the New API Public Awareness Website Full Episode Transcript:
Russel Treat: Welcome to the “Pipeliners Podcast,” episode 274 sponsored by the American Petroleum Institute, driving safety, environmental protection, and sustainability across the natural gas and oil industry through world class standards and safety programs.
Since its formation as a standard setting organization in 1919, API has developed more than 800 standards to enhance industry operations worldwide. Find out more about API at API.org.
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. We appreciate your taking the time. To show the appreciation, we give away a customized YETI tumbler to one listener every episode. This week our winner is Erica Fink with DTE Energy. Congratulations, Erica. Your YETI is on its way. To learn how you can win this signature prize, stick around till the end of the episode.
This week, Terri Larson returns to talk to us about API 1162 in the new API public awareness website. Terri, welcome back to the Pipeliners Podcast.
Terri Larson: Thanks for having me. I’m glad to be back. Feels like I didn’t leave.
Russel: I know. I know. I guess we’ve done three episodes now in pretty quick succession. When I find somebody, it’s got lots of good information, I like to keep going to the wells. There you go.
Terri: It works for me.
Russel: We’re back on to talk about API 1162 again. Before we dive in, to give viewers a quick little bit about yourself, what you do, and how you got into the business.
Terri: I started my career working in the news media. That was what I wanted to be from a little kid up to college. I never deviated. Worked in news media, primarily in TV news for about eight or nine years, and then it became something I just didn’t really want to be part of anymore.
I transitioned over to public relations and eventually worked my way over to Enbridge in 2005. Part of the job at Enbridge, at that time, was the public education program. They were transitioning.
First edition of 1162 had been published, so they were transitioning over to its public awareness program or what it would look like, and then just manage that process. I’ve been doing public awareness for pipelines ever since.
Russel: Awesome. We recently did an episode. It was episode 249. We covered what the content of 1162 is in some depth, but it might be helpful just at a high level to talk about what’s new or different in 1162.
Then, for the listeners, what we’re going to do is we’re going to talk about the guidance website and then some recommendations for how to implement a standard that’s fairly different from the old standard.
Terri: With the third edition of 1162, we had a really good starting point with the first edition. That was a good first step – it’s published in 2003 – to communicate with stakeholders along pipelines and associated facilities, but there were definitely some flaws with it.
The second edition attempted to fix those flaws. Unfortunately, the second edition was never incorporated by reference into regulation by PHMSA. It was published in 2010. It was reaffirmed in 2015.
2017 is when we started the process to review again and start the process of creating the third edition, intending again to fix some of what needed to be addressed from the first edition, hoping obviously that this time we get incorporated by reference.
We had more information when we started the third edition. Then the team that did the second edition had available to them. In 2011, PHMSA had kicked off a round of significant public awareness audits. The second edition team didn’t have the data, didn’t have the findings from that process available to them, and so we had that.
PHMSA created a SWOT, strengths, weaknesses, opportunities, threats, report as a result of all of the audits they did of operators public awareness programs after completion of the first cycle under the first edition, and then came back with some recommendations. We had that available to us.
Things like streamlining messages. Operators have been talking for years about there’s too many messages, and they’re not all relevant from a baseline program perspective as one example.
We didn’t necessarily, in the third edition, we haven’t necessarily, to be honest, we haven’t reduced the number of messages, but we’ve made them more targeted and we’ve made them more specific to safety.
“Is a baseline message going to advance safety?” “Yes.” “Great. It stays as the baseline.” “No.” “Then it moves to supplemental.” That became a very clear line for us as we were trying to figure out how to split those up.
One example, for example in the first edition, a baseline required message is the purpose of pipelines. What is the purpose of pipelines? Now, we needed that information from an education standpoint, but did it ever really need to be a baseline required message that every operator had to relay?
In the third edition, we bumped that down just to a supplemental message. It’s still important information. People still need to know why pipelines are important, how they operate, the reliability, and so on, but it doesn’t affect safety as a message so we bumped it down to supplemental.
There’s a lot of debate. This is a very passionate team involved in creating the third edition.
Russel: Standard committees often are.
Terri: Yeah, a lot of passion in the room. We had a lot of arguments, we had a lot of debates. There were some meetings that produced more headaches than productive work. Some on the team would probably agree with me on that.
In the end we all had the same objective, and that was to create a document that would advance communication, advance safety of communities around pipelines, and just help us communicate more effectively, and help us engage more effectively.
Russel: It’s interesting too. In the current 1162 that’s incorporated into the PHMSA regulations by reference is first edition. When was that published? What year?
Terri: That was published in 2003.
Russel: Yeah, so that’s 20 years ago. Yes. Things have changed a little bit around how we communicate in the last 20 years do you think?
Terri: A little. Social media didn’t even exist then. Digital platforms, companies were starting to have websites, but they didn’t know what in the heck to do with them. A lot has changed about how we communicate now. Email, how much do we all use email now to communicate with people? Text messaging.
There’s just so much more available to us now. The first edition didn’t account for any of that because it predated all that technology, or at least predated it in the way that we use it now. That was a key consideration as we went into this third edition, is how do we evolve the standard to allow the ways that we communicate now and allow us to communicate in the way people want to receive information.
Every pipeline operator, we all joke, we’re all producing these direct mail pieces, brochures, and so on, and they can be very effective. I don’t want to downplay that at all. The joke is it’s just going in the recycle bin.
When that is the primary method really, that operators are using to communicate with people who live and work along their pipeline rights of way, we all know they’re going in their recycle bin or the trash bin.
When we can incorporate email, text messaging, social media, and other tactics, other ways of communicating, other channels, maybe some of those are baseline and some of those are not, are never going to be baseline. It depends on the audience and the operator’s program and where they operate.
An email list for emergency responders, if you’ve got a really good list for emergency responders in your operating area may be way more effective than a mailed piece will ever be. It comes down if you know your audience, which there are some new baseline requirements related to stakeholder identification.
If you know your audience, you know who you’re trying to communicate with, you’ve asked them how they want to be communicated with, and now we can actually action that through the third edition. Which is really cool.
Russel: Yeah. There’s a lot of new content. Let’s transition. I want to talk about the guidance website because the guidance website’s brand new. As we were teeing up this podcast episode, I opened up my browser here and I brought it up.
The first thing I did is I went to the first tab and there was information in there about key changes in the first edition. I clicked on that page and then I started scrolling down and I went…
Terri: And you keep scrolling.
Russel: Goodness. It’s like is there any section of the document that you didn’t change?
Russel: It kind of looks like it didn’t change at all.
Terri: It’s a red line explosion. The word document that we were working from is a red line explosion. What we wanted to do with this website, so really the intent of the website is to provide guidance for operators.
To talk about things that have changed and provide some guidance on how to implement, how to consider those changes within your program. We didn’t want to do a “you must do it this way” because everyone’s going to do it a little differently based on their company, their operating area, and their stakeholders.
Especially for new people coming into public awareness or, should there be a new operator, we wanted to make sure that it was clear what you needed to do. One of the commitments that we made to the task group when we began developing this website – and certainly began talking about it also the commitment we made to our regulators – was a level of transparency.
This key changes tab, that started as a spreadsheet that I developed and where I just went, “In each section, what has changed?” Because we didn’t really have that level of documentation. As I said, the document itself is just an explosion of red line and track changes and it’s hard to navigate.
That was something we struggled with as well. We didn’t really have good documentation when we began the process on the third edition of what had changed from the first to the second editions. We wanted to make sure that there was some documentation and we wanted it available for everybody to see.
Now is it every comma and every…? No, but pretty much everything else is covered in this spreadsheet.
Russel: Yeah. There’s a link in the page to actually download all the content as a spreadsheet.
Terri: As Excel spreadsheet.
Russel: Yeah, it could be really handy right there.
Terri: Oh, yes.
Russel: Maybe if you could walk us through the website and how you really view operators using it.
Terri: We wanted to frame the site around PDCA – Plan, Do, Check, Act, which is the iterative framework that the RP itself is based on. As you know, that comes from 1173, which was pipeline safety management systems.
That was intentional. From our very first meeting back in 2017, we knew that we wanted to frame public awareness for this edition around that PDCA approach. With the website, for example, the first tab is just the third edition. What do you need to know about the third edition?
From there, you get its Plan, it’s Do, it’s Check. Each section in the document is clearly identified as where it falls in PDCA. Under plan, for example, you have introducing new hazards, messaging requirements, language requirements, stakeholder identification. Things that you need to know as you’re building your plan.
Under delivery, which is Do, using collaborative approaches. How can we use collaborative approaches? That’s a new one in the third edition. It wasn’t addressed previously in the first or the second editions. It’s how operators have been using collaborative programs and efforts and initiative really well, but they haven’t been able to take credit for them in a meaningful way.
Now they can, and we’ve outlined that under that Do section on the website. The Do is really the delivery of your program. What do you need to know? Using digital platforms is another example of what we have in there. Then Check, which is measurement. How do you measure the effectiveness of your program?
A big change in the measurement section of this in the third edition, is moving towards standardized questions. So that at least for the baseline questions, no matter the survey instruments, when operators are evaluating the effectiveness of their programs, the questions are the same. You have to use those questions.
There is some customization that’s allowable and that’s in the document, but everybody has to use those questions. Which gives us apples to apples comparisons and trending data that we haven’t had before. We said we did, but we didn’t.
Russel: It gives it to us more broadly than a single operator.
Terri: That’s right.
Russel: We can all share that data and then do analysis across how we are doing as an industry versus just how we are doing as an operator.
Terri: That’s exactly right. Now, we’ve said all along that we were able to do that, but we really couldn’t because we weren’t using the same questions and the same methodology. That’s a big change that’s in this third edition.
That’s a learning that we got from looking at peer industries – I think it actually might have been the chemicals industry – how are other peer industries managing measurement of these types of programs?
Russel: I actually had somebody from the aviation industry who’s involved in aviation safety and we were having a very similar conversation. He said that one of the things they really found as an industry to improve safety is when they started normalizing the questions and the scoring.
Terri: That’s exactly right.
Russel: You can argue about whether it is the right way to do it or not. That wasn’t nearly as important as having everybody doing it the same way, because that’s way more valuable than just the subtle distinctions. Then when you make a change, you make it across the entire industry.
Terri: That’s what we’ve done here. You can, if you’re a transmission operator, versus a gathering operator, versus a distribution operator, that’s where you can customize. You can customize the product. You’re not asking about crude oil if you don’t transport crude oil on your system, right?
The stem of the question, the basic question itself and the methodology, those are now standardized. We do have supplemental questions as well, and you can add in any other questions you want, but you have to use those core questions.
The move towards behavior intent instead of behavior change is another really good example of learning from a peer industry. The first edition required operators, and this is still part of measurement, to determine whether stakeholders were changing their behaviors based on the information you were providing through your program.
That was impossible to measure. It’s so subjective. There were some things we could use to help determine that. For example, is there an increase in locate tickets, locate requests? Is there an increase in the number of calls to an operator’s emergency number?
There were some of those types of activities that we could then extrapolate and say we’ll see they’re changing their behavior because they’re calling more often for locates. They’re calling more often to the emergency number to report X, Y, and Z. Other than that, it was extremely difficult to measure.
The second edition eliminated it all together. Which PHMSA, our regulator, didn’t want to go that far. In the third edition, that’s another area where we looked at peer industries – how are other industries doing this? We came down to behavior intent instead of behavior change.
“Will you call 811 in the future?” “Yes, I will.” “No, I won’t.” That gives them something they can answer about being the stakeholders. It makes for much more meaningful engagement from the operators. Behavior intent, what we found from those peer industries is a really strong predictor of whether a stakeholder will actually engage in the behavior that we want them to engage in.
It’s a better signal of behavior change than trying to measure behavior change, which is interesting. The document is full of changes like that.
Russel: That’s a leading indicator versus a following.
Terri: Yes. Versus lagging.
Russel: Really for good safety programs, you want a propensity of leading indicators. You need some following as well, but the leading indicators are key because that’s how you know if you’re changing the direction.
It takes a lot longer to get to the lagging indicator. You could be doing the wrong thing for a much longer time before you found out it was the wrong thing.
Terri: Right. One thing that operators will not find on this website, one is it’s not a regurgitation of the document. You can access the standard through the website, but it’s not a regurgitation of the standard itself. They’re also not going to find an act section, which is the A in PDCA.
That’s because you can act on learnings and findings at any point in the cycle of your program. There’s also not an Act section in the document itself. So we really focus on the Plan, the Do, and the Check. Act you can do at any point. That’s really two things that operators will not find on this website.
Everything else we’ve tried to make sure is available. If it’s not now, then it probably will be in the future.
Russel: I got to say this about API. They’ve really done a good job of beginning to put useful guidance and tools out for the various standards they’re implementing, and that this is becoming thematic as they’re getting new standards out. They originally did this with the whole pipeline safety management standard.
Then, when they put out the new 1175, they follow the same approach. This is becoming a consistent approach particularly for those things that are very process central.
Terri: They’re reading the room and they’re seeing how their stakeholders, or operators, need information and want to be able to find information. They’re going through this process themselves.
Russel: Yeah, exactly. Great segue, because now I want to ask you, because this tees up a really interesting question. I’ve got a 20 year old communication standard that’s incorporated by reference. I’ve got a brand new revision to that standard that’s materially different to what’s incorporated by reference. I’m an operator. What the heck do I do about that?
Terri: It’s such an interesting question. I know it’s on the minds of probably every operator who has a public awareness program which is every pipeline operator. First things first, yes, there are a lot of changes in the third edition. If you read the RP, what you’ll find is that the changes that are in the third edition will also help you meet the requirements of the first edition.
We’ve strengthened areas. We’ve clarified where things needed to be clarified. We’ve added definitions, where…Like liaison, for example, didn’t have a standard definition across any of the federal agencies. We’ve looked at the dictionary, and we came up with one.
That’s something that’s been a requirement. That was a requirement before public awareness regulations became effective in 2006. That was already on the books for emergency response, but there was no real definition of it.
It is voluntary right now. The third edition is voluntary until, fingers crossed, it’s incorporated by reference into regulation by PHMSA. An operator could simply choose to ignore it for now. Obviously, we hope that they won’t.
If you read through the RP and you look at the different communication methods, streamlining and clarification on messages, the requirements now for a process to identify stakeholder audiences, a process or a method to identify languages that are going to be needed on your system, with very few exceptions.
If you were to implement all of those requirements or most of them, you’re still going to meet the requirements of the first edition. You’re still going to pass an audit. You might just have a stronger program.
Russel: Had you guys put together or done the analysis around what’s in the original edition, first edition, versus what’s in the third edition, versus what’s actually specified in the regulations?
Terri: The key changes page on the website that you mentioned earlier – the website is a fabulous resource – that’s specifically the key changes from the first edition. The first edition, there’s the preamble language in the regulations, but it’s all reflected in that first edition.
If you look at that page on the website or you download the Excel spreadsheet, whichever is easier, and everyone’s going to have a different way of doing it, that’ll give you probably some really good guidance on what’s changed from that first edition that you need to look at.
There are some big ones, the PDCA approach. There are collaborative programs. We’ve also added collaborative programs into measurement, because you can participate in a collaborative program. Then, there’s the measurement aspect of the program itself that you are participating in, and does it help you meet your program objectives.
Setting program objectives is a big one. We’ve always had program objectives. The first edition and the third edition, they’re a little bit different now. Now, it’s awareness, prevention, and recognition and response.
Operators can add their own objectives on top of that, but they have to have objectives from those three areas. Social media, digital platforms, probably for right now until, again, hopefully knock on wood or cross your fingers, throw salt over your shoulder, whatever you normally do to bring good luck.
We’ll have flexibility on social media and digital platforms and text and email, at some point, maybe being available as baseline methods if they’re appropriate for your audience, but they can absolutely be used as supplemental communication methods now.
Again, that will help strengthen your program. One of the biggest issues we’ve had is if you don’t communicate with people where they are, you’re missing them. If you’re counting on a mailer, as an example, that’s the only baseline communication you’re having with a particular stakeholder. If it goes on a recycle bin, they’ve never even read it.
Russel: Nowadays, there’s people that don’t even check their mail.
Terri: Yeah, my mom is one of those.
Russel: I do everything online. I don’t need mail. Right?
Terri: Right, yeah. It’s all junk now.
Russel: Side story. I was talking to a company, and they had a young man. When I say young man, he’s in his 30s. He had never in his life received a personal letter. I sat down and wrote him a handwritten personal letter, posted it, stamped it, and mailed it to Canada. He got it, and he’s like, “What the heck is this?” I didn’t tell him I was doing it.
The next time I talk to him, he says, “That was so very cool.”
Terri: That’s awesome.
Russel: There you go.
Terri: The kids aren’t even learning cursive a lot of the time in many schools now either. Letter writing, what’s that?
Russel: We can talk in code if we don’t want our kids to know what we’re doing, we just write cursive to one another.
Terri: Right. They have the abbreviations. My daughter talks in those abbreviations. We’ll be in the middle of a conversation. She’s like, “Pls.” Can you just say the word “please”? It’s actually a whole lot less effort. Just say please instead of pls, but again, know your audience, right?
Russel: Right, right. You have a point. Right. I’m scanning the website, and I’m looking through these changes. A lot of them are things that are just clarifications, additional definition, additional guidance. There are not really changes to what you need to do.
I could see where if I were getting audited, I was doing social, and I had really good measurement, I would think a regulator’s going to look at that positively.
Terri: Yeah. That’s what we would call an acceptable deviation. If you have documentation, you can see the effect of it. You can see people engaging and you can show all that documentation, then yeah. Do it. Please.
So many companies are still afraid of social media and afraid to use it in this context. If it doesn’t relate to their corporate branding efforts. Which is unfortunate. There’s so much opportunity using those channels for this.
Russel: It requires a different mindset.
Terri: It does.
Russel: It takes a while because most of what we hear about social media is not good. Those people who really understand it know how to work with it, there’s a lot of things you can do with it that are very positive. It’s like any other tool, right?
Terri: Yeah. Absolutely. It can be a good thing and unfortunately, sometimes it can be a negative thing.
Again, know your audience, right? Any good communication program, that’s the first step. If you haven’t gone through the process to really and truly identify who you’re trying to communicate with, you’re wasting money on everything else. The same is true for public awareness programs.
Russel: I want to ask one last question, and that is around the third edition actually getting incorporated by reference. What is your sense of that as a possibility? I know that PHMSA has been putting out some notices of administrative change related to modernizing the standards incorporated by reference holistically.
What are your thoughts on that? Do you have a crystal ball?
Terri: I don’t. I don’t have a magic eight ball either. If I did have one, they may not be functioning on this particular topic anyway. We, and when I say we here, I mean API really, it’s they who continue to advocate with PHMSA. PHMSA knows that there needs to be changes to public awareness.
They are very hyper-aware of the issues with a 20 year old standard around communication when communication has changed so drastically. They are very clear on that. They’ve made that very obvious from the start of this process. It’s just is the standard what they’re looking for.
There are some things, and you could say the same thing about every operator and every vendor and consultant who was in the room for this process. There are things that they really like about the standard, there are things that they’re not going to like about the standard.
Can we meet in the middle somewhere? All that remains to be seen. They do have some options. They can incorporate, they can choose not to incorporate, or they could incorporate parts of it. That remains to be seen. API continues to advocate strongly because we need to make changes.
This is really good…Is it the silver bullet that’s going to fix any problems? No. No document is going to be that silver bullet, but it’s a really good step down the road to getting us to better safety. To get people to pay attention to safety messages and actually take some of those actions.
Russel: Simply having some guidance for how to use some of the newer technologies effectively to support public awareness and stakeholder engagement, is critical for what we’re trying to do as an industry.
Kudos to API, yourself, and the whole committee for getting it out. I know how much work that is and how hard it is to get those things across the finish line. That’s awesome. Kudos on the website too. I think it’s really cool.
Terri: Thank you. Yeah, we’re really proud of it.
Russel: I don’t know when we’ll do our next podcast episode, but at our current rate could be soon.
Terri: It could be soon.
Russel: All right. Thanks Terri.
Terri: Thank you. Appreciate it.
Russel: Hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Terri. Just a reminder, before you go, you should register to win our customized pipeline podcast YETI tumbler. Simply visit PipelinePodcastNetwork.com/Win and in yourself in the drawing. If you have ideas, questions, or topics you’d be interested in please let me 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 week.
Transcription by CastingWords