AS 2885.1 Draft for Public Comment

PART 1 RELEASED FOR PUBLIC COMMENT

AS 2885.1 Design and Construction of Petroleum Pipelines – has been released for public comment, open now until December 1, 2017.

It is almost 300 pages long, so please make some time to review it and provide comment.

The process for downloading the (free) draft from Standards Australia is the same as for Part 6. The process for, and observations on, commenting is covered here and here.

By the way – Part 6 (Safety Management for Pipelines) public comment has been extended until October 11.

AS 3862:2002 Amd 1 Published

AS 3862:2002, External FBE Coating for Steel Pipes has had an amendment published.  The amendment incorporates text corrections, corrections to cross-references, improves Section 6.2 Coating Tests, and replaces a number of items in the Appendices.

The amendment is free of charge from SAI Global (and this only includes the amended text, not the full Standard). Purchase of the full Standard, incorporating Amendment 1 directly within the text, would cost about $200 on SAI Global. 

A full revision to AS 3862, incorporating use of dual layer coating, will be underway soon but will not be published until late 2018 at the earliest.

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Compile it.

Does anyone remember the old computer programs, that you had to “compile”, and then wait to see how many programming errors you had?  I learned programming on Fortan77, way back in the late 80s/early 90s.  And that was always an ‘edge of the seat’ moment, when you’d done all your hard work to, say, program some complicated calculation like the cosine of an angle, and then you sit back and …. wait for it… “success!”.  I still remember the agony of a failure, and having to go back into the code to figure out what had gone wrong.

Ok, so, same thing with the upload of the Standards template into the comment form.  Today I submitted another 20 comments, via the template.  It’s not any easier, it’s still tedious, but it’s all we’ve got.

It took me an hour.  That was 20 pages of Part 6, and I had 20 comments (mostly editorial); and this is only Sections 1-3.  I still have 60 pages to go, although the mark-ups will definitely tail off in the Appendices, especially the informative ones.

Here’s a sample of some of my comments.  (yes, I’m a little pedantic; perhaps I was an editor in another life.  But – language is everything, as anyone who has to interpret these Standards knows.)

On these ones, I figured out that I could copy/paste the text directly from the pdf version of the Draft, so I actually didn’t have to type it all in.

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The good thing about using the Template method, is that you keep a record of your comments.

The next step is to Upload the file to the Standards site.

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Fortunately there are no rules about what you name the file, just browse to it, but – it is essential that the Section and Comment Type match the options that are provided in the footer on the first page.  And that the Section Identifier is only a number, no letters.

This is where “compile” comes in.

I failed.

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But never mind.  Somewhat tedious and painful but necessary process. Below are highlighted my mistakes.  Easily fixed.  Reminder to get it right before uploading.  Note to self:  Check your work!

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And, I didn’t take a screenshot after it successfully uploaded (compiled!).  I guess I was just too relieved to have finally got it right.

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So, there is no limit as to how many times you can upload comments – once is not enough.

I’m off to do more editing.  I won’t post progress here anymore.

Reminder:  Public Comment closes on Wednesday Sept 13th.  Don’t leave your commenting to the last minute – you’ll need an hour at least. (!)

 

Comment here.

Today I submitted 4 comments to Standards on Part 6, via the web-based commenting form.

The Standards commenting interface was pretty intuitive, and easy to use; I was impressed.

Although, it’s tedious! Especially for editorial mark-ups, and especially if you have a lot of them (or course then, you’d use the Word template, which I’ll be doing later this week).

And yes it would be easier to just send in a marked-up version of the whole text….  But, no, it must be done this way via the comment form, (individually for each change) so that we the committee can group and sort the comments together for review.

So from a commenter point of view, submitting comments is tedious.

But from a committee member point of view, sorry about that.  It makes it easier for your poor volunteer committee member, think of it that way.

(by the way, if you have a stack of comments and don’t have time to transcribe them into Standard’s system, …. I can do it for you, for a price…! … get in touch… susan{at}sajconsulting.com.au…)

Anyway: I submitted four comments today:  two Editorial, one Technical, and one General comment.

These labels help the committee to identify what the purpose of the comment is, and how much time/attention to assign to them.  Editorial comments (addressing obvious typos or minor word changes) are welcome and easy to address.  But when you are proposing a change that may change the intent of the paragraph, that should be classified as Technical.   General comments, as I understand it, apply across the Standard, but you still need to assign it to a Section/Subsection, so I just used “Introduction” if it’s across more than one section (see example further below).

My first two comments were editorial, and editorial comments are tedious to fill out, but, it must be done.  Sorry bout that.

By the way –  in Section 6.4, we’ve already picked up the incorrect cross reference to Clause 1.5.4 which should be referencing Clause 1.6.5.  Save time: You don’t need to submit that one.

Ok so for an example, here’s a suggested word change in the Foreword, which I think makes the sentence more sensical.  Yes I had to type it all out.

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When using the online form, you can submit multiple comments by choosing “Add another comment” on the left side:

 

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That results in this warning, which looks scary but it’s not.  The system just creates another form below the first one for you.

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And here is a Technical comment I provided, for Section 2.3 Primary Location Class.  Technical comments can be hard to ‘explain’, and I sympathise – I had a hard time explaining this one.  But, give it your best shot.  We’ll figure out what you’re getting at.

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And here is a “General” comment I’ve put in, to highlight something that the Part 0 committee is contemplating, for consistency across the suite of Standards. (Shown here for your information and consideration).

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And when you’re done – “submit comments” – the green button on the right side – and it’s gone, never to be seen by you again…

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And then this is what the committee sees:

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Hope this helps demystify the comment process for the online form.

Later this week I’ll be uploading another bunch of comments using the word template method.

Good luck with your Part 6 review and commenting.

Define this.

Definitions are obviously an important part of any document or communication – an agreed definition helps achieve effective communication.

Getting to an agreed definition can be incredibly difficult. This is particularly true, and particularly difficult, when writing Standards.

Currently, AS2885.6 (“Part 6”) is out for public comment, closing on or about September 13th (we are trying for an extension).

We had intended that in the Part 6 Public Comment version, the defined terms would appear in small caps.  Unfortunately that didn’t happen, but we intend that the published version will.

Here is what it will look like – this is the Foreword for Part 6, with the small caps:

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I think it looks quite good – and draws attention to our defined terms.

Definitions across the suite of AS 2885 Parts have been vexing to keep consistent.  We now have a proposed approach to collect common definitions that are used across multiple parts, into Part 0 (which is also currently under revision).  The logistics of this strategy means that when Part 6 and Part 1 are published, the revised Part 0 will not be ready yet.  And so there will be overlap and duplication.

The Public Comment version spells out the definitions of common (Part 0) terms in full (these are the definitions that in the Public Comment version have [SOURCE: AS 2885.0 – 2007]. (should have referred to AS 2885.0-2008).

When Part 6 is published, the definitions for these common items will simply be “See Part 0”.  This helps to achieve consistency, for when the definitions need to change over time.  For example the definition of Competent Person is changing slightly with the next Part 0 revision (see below).

The definitions below should be well known and understood in the Australian pipeline industry. They already currently appear in Part 0, and so the published version of Part 6 will simply read “See Part 0.” and not have the full definition.

Approved/Approval

Approved by the Licensee or the Licensee’s delegate, and includes obtaining the approval of the relevant regulatory authority where this is legally required. Approval requires a conscious act and is formally documented.

Competent/Competent Person (or organisation)

A person who has an appropriate combination of knowledge, skills (the current definition has ‘expertise’) and experience to safely and effectively perform the task required.

Licensee

The entity that the regulatory authority holds accountable for the pipeline.

NOTES:

1 The Licensee may or may not be the pipeline owner and may or may not be a licence holder under legislation.

2 The Licensee may be a different entity at different points in the pipeline life cycle from design through construction to operation and abandonment.

Regulatory Authority

An authority with responsibility to administer legislation relating to pipelines covered by this Standard.

 

There will be push-back and concern on the implementation of common definitions into one Part (Part 0), we expect that.  The initial response will be, “but I only ever use Part 3 (or Part 5, or whatever)…  and now it’s not ‘stand-alone’. ”

Our principle has always been that everyone should be familiar with at least Part 0 across all roles, and soon almost everyone will be required to be familiar with Part 6, since it applies across the entire pipeline lifecycle.  So it’s not quite a valid argument against collecting common definitions into Part 0.

We have had conflicting definitions in the past, and so we are now aiming for ‘one version of the truth’ – and that means having definitions in only one place.

And, it will be a process, not instantaneous.  The first step is moving the common definitions into Part 0, with the resulting duplication that will incur.  Due to publication schedules, of course we will have duplication, and a number of full definitions (instead of just “see Part 0”) will have to appear in Part 1 and Part 6 (for example Pipeline System, Mainline Pipe, Pipeline Assemblies, and Stations among others), as well as Part 0 when it is published.  That duplication will disappear once amendments or revisions are done.

Here are proposed Part 6 / Part 1 / Part 0 common definitions (also relevant in Part 2, Part 3, and Part 5…) for those four tricky terms:

Pipeline System:  System for safe transmission of fluid, comprising mainline pipe together with any necessary stations and other facilities.

Mainline Pipe:  Those parts of a pipeline system between stations or pipeline assemblies and comprising only linepipe and cold field bends, excluding induction bends.

Pipeline Assembly:  An assembly of pipe and components that allows for a single simple function such as pipeline isolation, diversion of flow, separation of phases or launching or receiving pigs.  NOTE: See also Station.  Pipeline assemblies include but are not limited to scraper assemblies, mainline valve assemblies and branch connection assemblies.

Station:  A facility that allows for control, measurement or pressure maintenance of pipeline fluids, including compressor and pump stations, pressure regulation and metering facilities.  Other facilities that involve frequent operational activity may also be designated stations for the purpose of this Standard.  In addition to piping and equipment, a station includes other infrastructure such as control facilities, power supply, and security fencing.  Note: a station may include pipeline assemblies as well as station piping and other equipment and infrastructure. 

 

Have you reviewed the Part 6 Public Comment draft yet?

Later this week – my trials and tribulations with filling out the Public Comment form with my own mark-ups on Part 6…

 

 

 

 

And now? Part 1 / Part 6 update

I can report a little progress… but just a little.  The drafting leads for Part 1 (that’s me, Peter and James) have received it back from Standards today, and so it will now have a last high-level review next week before it goes to the Publisher.  We’re told that it will be with the Publisher for about 10 days in their queue, and then be available for Public Comment.

So my best guess for availability for Part 1 public comment, is around mid-September.

It looks good at the moment.  And I really like the SMALL CAPS for defined terms, it really makes those DEFINED TERMS ‘pop’ out of the page.  Keep in mind when reading it, that this is a Standard, not a tech spec, or a novel, so yes it reads awkwardly in places, almost like CONTRACT documents do, but I think it’s a GOOD CHANGE.

Which reminds me, Part 6 Public Comment closes on Wednesday September 13th.

We are also intending to use SMALL CAPS for DEFINED TERMS in Part 6 as well, but for the public comment draft they got stripped out by the stylist unfortunately.

We are pursuing an extension to the Part 6 public comment deadline, beyond September 13th, so that there is overlap between the two Parts, …but that extension is not assured from Standards.  So dig out that email / link / dusty Part 6 document on the shelf, and get reviewing.

I’ll keep you posted.