AS 2885.1: read (past tense)

A few weeks ago, I set myself a project to read the 300-page Part 1 from cover to cover.  I allocated an hour a day, which equated to (disappointingly sometimes) only 15 – 20 pages at a time.  Typically I did the reading first thing in the morning, at sunrise (being in Brisbane that ends up at around 4:30am this time of year…although truth be known the alarm went off at 5 or 5:30, and I’d get a coffee and start reading).

Some might say, that’s a bit backwards – this stuff puts you to sleep, not wakes you up.

Some of it I read quite deeply and carefully, to make sure I understood it, and could apply it.  Other parts I confess I only read for clarity and grammar, looking for typos and glaring errors (the fibreglass pipe appendix, and the CO2 appendix, fall into this category).

Anyway, over the 3 weeks I got it done, and it feels good.

Next is the task of providing the resulting comments on the Standards website – disappointingly there are dozens of typo and reference errors that will have to be put in (I thought Standards would pick those up).

Here are some items to be aware of during this last week of Public Comment on Part 1:

  1. Definitions:  For terms that are used in more than one of the Parts, these will be collected into Part 0 and defined there.  In each of the Parts that the defined term is used, the term will be listed in the Definition section, but will only contain “Refer to AS 2885.0”.
  2. “This Standard”, “The Standard”, “the AS 2885 suite of Standards”:  use of these phrases has crept in to many locations, and sometimes it is not clear what is meant (Is “this Standard” the one you’re reading, or the entire suite…”).  We are attempting to clarify this amongst all of the Parts.  We’ll try to be consistent with “the AS 2885 suite of Standards” when that is meant, and use “this Standard” when only the Part being read is meant.
  3. Section 5.4.4: Design for Protection (physical and procedural controls) – the previous “1+1 and 2+2” approach to determining how many controls are required for a particular Location Class has been re-phrased to “All reasonably practicable methods shall be adopted” (it is not a simple recipe table anymore), followed by the requirements that shall be adopted for the different location classes.  The intent has not changed – just the phrasing.
  4. Appendix D, Guidance for use of a Design Factor above 0.72: this is a very useful guideline for when contemplating a 0.8DF pipeline.
  5. Part 1 = New Pipelines (or modifications):  This edition of Part 1 only contain requirements for new pipelines (or modifications).  All requirements for existing pipelines has been moved to Part 3(Operations) or Part 6 (SMS).  We recognise there will be a gap of a few months in publication between Part 1/6 (Q2 2018) and Part 3 (Q3 2018), and so as an industry we will work to bridge that gap with industry communications if required.


Thank you for your time and efforts to review the Standards.


AS 4822 revision: Public Comment

AS 4822, External field joint coatings for steel pipelines is out for public comment, closing on 18-Jan-2018.

As with all Public Commenting, comments must be provided through the Standards website in order to be considered.

Here’s some more information:

The objective of the AS 4822 Standard is to provide manufacturers, suppliers, specifiers, and users of oil and gas pipelines information on the application of and testing requirements for external field joint coatings (FJCs) of seamless or welded steel pipelines for onshore steel pipelines.

This revision updates requirements, taking into account the latest version of ISO 21809-3 and includes a new joint coating type – Amorphous low viscosity polyolefin coating.

National Energy… (edited 24/11/17)

Today I listened in on the publically available webcast about the National Energy Guarantee (NEG) proposal given by the Chair of the Energy Security Board (ESB), Dr Kerry Schott.

The thing with webcasts is that you never know how many are ‘there’ listening in – it could’ve been just me, or it could’ve been a cast of thousands. 

This screenshot shows the structure of the ESB, appointed in July by COAG:


The first 20 minutes was a fairly unsurprising summary of the ESB and its proposed National Energy Guarantee, which if you’ve read any of the press on this, there was nothing new.  It went over the now well known three goals of Affordability, Reliability, and meeting emissions targets.  Fine and understandable.

I like this depiction showing the different ways proposed to meet the NEG:


The presentation highlighted that ‘retailers enter contracts with generators that are financially sound” (ie, the retailer will make money) (no thought for the consumer).  And then it was said that “they now need to focus on reliability and emissions too”, implying that this wasn’t a focus of the retailers.

A couple of times it was noted that the (intermittent) renewables cost installation were decreasing, nay ‘plummeting”.  Ok, good. But later is wasn’t quite clear if those costs would continue to ‘plummet’ when the reliability requirement was brought into force (not until 2019, if approved at all).

The next 20 minutes were a Q&A session from people on the webcast.   The questions asked that I made a note of were:

  • “Will the reliability requirement be set too high, meaning that consumers pay for generation that is not needed?”
  • “Is the real cost of wind/solar/batteries actually factored into the modelling?”
  • “Will the NEG dis-incentivise renewables?”

You can imagine the generic responses, “no, it shouldn’t”, “yes, we think it does”, and “no, it shouldn’t”… so those didn’t reveal very much.

Of interest were these two:

“What does NEG mean for gas” and “Will there be a future for thermal coal”.

The simplified answers are “not good” and “no”.

The answer to the gas question focussed on the high current price of gas and that is the problem.  So it is a lost opportunity.  The answer also alluded to the next decades being about innovative answers to dispatchability , pumped hydro, etc.

Ok, so, I guess no real surprise.

But – two things – ‘the next decades’ means we still need gas for that time.  And I’d like to point out that pumped hydro relies on the rain and the climate, and I’m not sure we can say that hydro is 100% dispatchable, because what if there is a drought in the area of the dams?  And what is the NIMBY crowd going to say about all these dams being installed and flooding the land (I realise the pumped hydro proposals are being placed in remote ‘poor’ land areas, so that’s good).  I also wonder about the NIMBY crowd when solar farms and wind turbines end up in their backyard, affecting their farm or their country view.  No one really mentions the blight on the landscape that solar farms and wind turbines are.

EDIT 24Nov17:  I’d like to provide an edit here with information I received via email from Peter Tuft… clarifying that pumped hydro doesn’t rely on great amounts of rain, so I stand corrected:

“The essence of pumped hydro is that it does not require a large volume of water and is relatively independent of rainfall and runoff.  The same water just goes up and down between reservoirs.  The reservoirs don’t even need to be very big (maybe under a sq km) if the operating cycle is only a few hours of pumping then a few hours of generation, as would be needed to even out solar generation.  ANU have done a lot of work on this (Google “ANU pumped hydro”). Traditional hydro schemes are very different because they  do need to collect and store enough water to provide generation for maybe a year as opposed to a few hours.”

Thanks for the input Peter, much appreciated.


Anyway, ok, it’s the way of the future.  Ok, I get it.

Two things:

1) How long does your iPhone battery perform at 100%?  When it’s new, it lasts more than 24 hours without a charge.  A year later, and it barely lasts a day.  Do we know what the replacement timeframe is for those batteries being frantically installed now? Who pays for them to be replaced a year or two from now?

2) There was a fascinating presentation in August in Sydney, by Paul Gleeson of Aurecon, which outlined ‘The role of gas in Australia’s energy future”.  He was much more bullish about the logical need for gas, and it was a little inspiring.  His presentation was full of gems around ‘what really drives wholesale gas prices?’ (the weather), “what is the right generation mix for future demand?” (to be determined due to local conditions), and my favourite “the economies of firming with batteries and pumped hydro”.  This is where it shows the cost of full back up from batteries may not be as economical as we’d like it to be (I’ve taken the below screenshot from the Aurecon presentation):


Pumped hydro may be the better future, and we’ll just have to deal with it when there is a drought like Queensland had in 2007-2010 and the Wivenhoe dam was down to only like 8% capacity or something.

The future will be fascinating.  But I think there’s some life in the ole gas industry yet.




AS 2885.1 Public Draft – closes Dec. 1

Reminder that AS 2885.1 – Design and Construction Public Comment closes on December 1st.

We only have 3 weeks left; and it’s easy to say, “ yes, I’ll get to it, someday”.  Remember – time flies.

I’ve taken on the challenge of reading it cover-to-cover, and have allotted myself time to read a bit every day.

It takes me an hour to read 15-20 pages (comprehensive reading, not skimming.  Still, that pace was a surprise).

I don’t get to it every day, but with the Dec 1 deadline approaching, the pressure is on.  I’m on page 62 at the moment. That means if I do an hour every day, I’ll be done by around November 22.

But that’s how I’m going to get it done – an hour (or about 20 pages) a day (or more if I can, but I’m realistic, too).  Because after that, I still have to allocate time to translate my markups into the Standards Public Comment template, which will take another few hours.

It’s like a mini project.

In fact, I have created a project for this work within my management system, going so far as to give it a proper project number and a budget (time-based) and a schedule – and I’m treating it like any other important project.

Here are some suggestions for you to aspire to:

“Draft Expert”, first prize is that you read the Draft cover to cover and provide thoughtful, useful comments including the preferred wording.  Even better if, within your organisation, you have a workshop or group session (over lunch?) to discuss the Draft amongst yourselves to encourage reading and contribution with group input.

“Highly Knowledgeable”, second prize – is that you read the bit that you use the most, provide comment – AND also pick a random section that you’re not so familiar with, read that for clarity and understanding, as if you suddenly needed to understand and apply that section.

“Excellent Competence”which we should all at least strive for – is that you read the bits you use, and make sure the new Draft is suitable and agreeable and you can continue to perform your role competently within the new wording of the draft.  Just confirm for yourself that there are no clangers. Because then you don’t need to provide comment – it’s all good. And you can get on with your day.

And the wooden spoon?

Last prize goes to those who don’t read the Public Comment Draft at all, and then when it’s published in 2018 and you’re forced to finally read it because it’s now the version in place, and you’re surprised by the content and then you complain about it, bitterly, for years, after publication.

No wooden spoons out there, ok?


ME-038 and Standards Australia

Here is some more overview information about how Standards Australia and ME-038 fit together, to produce the portfolio of standards that ME-038 is responsible for.

Standards Australia ( is responsible for the development and adoption of standards in Australia. They also facilitate Australian participation in international standards development.

Standards Australia does not enforce, regulate or certify compliance to the Standards.
The website has plenty of information, but we’ll be specific and go directly to the Technical Committee area (circled in red below), where we’ll find information on the ME-038 Committee.



Industries are organised into 12 sectors, of which we are part of the Electrotechnology and Energy sector.


There are 60 active committees in our sector. (Also in the Electrotechnology and Energy Sector is AG-008 Gas Distribution, which looks after AS 4645 Gas Distribution pipelines, also an important Standard in our pipeline industry).


This page shows some useful details in a few tabs about ME-038; our active projects, our constitution, international relationships; published standards, and subcommittees.


The constitution of a Technical Committee (“Main Committee”) is made up of Nominating Organisations – we have about 20. The Nominating Organisation appoints a representative to represent the views of that nominating organisations’ interest during the development of a Standard.


So the Main Committee, representing the Nominating Organisations above, is a plenary committee, in that it sets the direction and guides the actions of the Subcommittees.

Subcommittees are different in that they are formed to “do the work” (more than just talk about it like the Main Committee does), and the membership is based on a person’s ability to contribute to the topic of the Standard, and their expertise, and knowledge of the topic. The subcommittee make-up is entirely up to the Subcommittee Chair to decide.


We currently have 7 active subcommittees, as listed above. Each subcommittee has between 8 – 35 people on it.  The first six listed above (00 – 05) match the AS 2885 Part that the subcommittee represents.  ME-038-08 subcommittee looks after the coatings/corrosion standards in our portfolio (AS 4822, AS 3862 and AS 1518).

After Part 6 (SMS) is published in 2018, we will create a subcommittee (hopefully logically -06) to shepherd that one through it’s early stages of life.

My previous recent “Overview” post referred to my ongoing love/hate (respect/disdain) relationship with Standards.  Here is a bit more information about that.

Once a Standard is in the system, there is a Project Manager who does the work to push it through the process of getting published.

First of all, you get what you pay for.  We don’t pay for the support the Standards gives us.  And they give us a LOT of support.  And sometimes it’s only worth about that much.

The SA Project Managers are overworked and overstretched and probably underpaid.  So that’s where I respect the work they do for us – it is enormous.

I have toyed with the idea of pursuing a self-published approach to our Standards, but in the end, I do see that it is a lot of work to do what they do in the publishing sense (such as the formatting, the logos, the rules – which are the bane of our existence sometimes… but they keep the document professional).  And yes, I resent it too that we then have to pay for the Standards that volunteer their time to develop the document.  But that’s the system, and like democracy, it’s the worst system except that there’s nothing better currently on offer.  I can’t justify us ‘going it alone’ unless there is a valid business model, which in the research I’ve done, would require industry contributions to fund it, otherwise we’re no better off than what we currently have with Standards Australia.

On the bright side, SA is modernising and updating their procedures and templates in recognition of the frustrations that committees have, and in recognition of the new technologies that are available now (online editing, videoconferencing, online training academy).

I’m really looking forward to the forecasted roll-out of utilising redline markups on Drafts for Public Comment.  It is currently being trialled on another set of Drafts.  That will be a huge help to everyone in order to more easily identify what’s change.  No word, though, on when that will be applied to our suite of documents.





AS 2885.6 (SMS) Update

Below is a stolen summary write-up – stolen from Peter Tuft, the chair of Subcommittee ME-038-01, responsible for the revision of Part 1and creation of Part 6.  It was an email he sent today to the ME-038-01 committee, and I thought it was simply good enough to post it here so I didn’t bother re-writing it, I’ve just checked with him that it was ok to copy it here, with minor contextual modifications:

“We (ME-038-01) have had a very successful meeting in Sydney over the past two days. 

“We reached a resolution on the fate of Section 4 of the public comment draft (High-Consequence Recognition) (HCR), which had the most Public Comment about it’s inclusion: so after much discussion, we’ve agreed to move it to an informative Appendix, with a view to getting industry experience with the concept and then refining it with the benefit of experience, and promoting it to being mandatory at a future revision.  (this is a workable outcome.  There were some industry objections to the inclusion of Section 4/HCR, and also some of the logistics of implementing the HCR requirement were enough that the committee concluded that having this mandatory at this stage may have been too big of a step – sj).

“We also got through almost all of the items flagged as needing face-to face-discussion, with only a few low-priority items missed. (he’s being modest.  We covered about 150 items in two days, plus the HCR discussion – that’s pretty good! – sj)

“Because of the extent of the changes, Standards Australia require that the document will be issued for public comment again, but via what they call “combined procedure” which involves simultaneous ME-038 Main Committee ballot and a Public Comment period of 6 weeks. Barring disaster, we should have an approved Standard at the end of that process. (we will, in effect, almost discourage public comment for that round – sj)

“So, we hope to have that next Public Comment draft published in early February or thereabouts, ideally before the annual ME-038 Main Committee meeting (20-21 Feb), subject to the vagaries of Standards Australia resourcing and the holiday season. (recall my ‘respect/disdain’ view of Standards… yes it’s a lot of work for them, and we appreciate it… and we also really hope they can meet the agreed schedule…-sj)

“Right now, the next step for the ME-038-01 committee is to finalise changes to the text, by mid-December.”

…And then there was a whole list of action items for us on the committee to get on to, referring to seven (only seven!) remaining comments that need discussion on the proposed resolution, and also referring to the 550 comments that were not discussed at the meeting but previously circulated to the committee – so we need to re-confirm no objections to the resolutions to those comments. 

In case you hadn’t heard, we had over 700 comments on this draft Part 6, surely a record for Standards Australia.

We are now aiming for Part 6 publication in Q2 2018.

And – reminder that Part 1 is currently out for Public Comment, closing on December 1.  



Overview Information

Another excellent annual APGA industry conference was held in mid-October 2017, in Cairns. Always an enjoyable 4-5 days of catching up with industry colleagues.

At this year’s conference, I presented on ‘The Story of the Standard”, an update of the status of our portfolio of Standards that apply to hydrocarbon pipelines.  It was well received, as a good overview of the way Standards Australia, ME-038, and the committees all work together to build our AS 2885 suite of standards.

I’ve been the chair of ME-038 Main Committee now for 3 years.  In that time, on a quick think about it, there are about three things that have changed, and three things that haven’t:

What has changed:

  • Industry ‘busy-ness’ has dropped off – there is obviously less pipeline work now than there was 3-5 years ago.
  • There is increased interest from people wanting to be on the committees (perhaps not realising the amount of work it can be)
  • There is improved collaboration amongst the Parts to AS 2885; we have several people who are on more than one committee, which helps coordinate the information that straddles the Parts.

What hasn’t changed:

  • Difficulties with Standards administration: there is a love/hate relationship here.  I know they are overworked and underappreciated, but when it takes over 8 weeks to get a Standard finalised for publication when it was projected to only take 10 days, well … love/hate, or maybe more like respect/disdain. I respect the work they do, but have disdain for the amount of time it sometimes takes to get it done.
  • The remarkably talented people on the committees.  I can’t say it enough, how impressive people on the committees are.  This is crème de la crème of the industry.
  • The amount of work involved in keeping our Standard current and useful: it’s simply an enormous amount of work.

Something that comes up often, that I’ll address here to clarify:  I do not get paid to be the Chair of the ME-038 Committee, and I cover my time and expenses to attend the committee and subcommittee meetings I go to.   Committee members who are employees of companies typically have time and expenses covered to attend meetings.   And thank you to the companies who support their employees this way – it is a win-win for everybody.  And kudos to those employees who are in a position of having to share the costs with their employer when the employer is reluctant to cover all of the costs. As far as I am aware, though, none of the independent consultants that belong to the ME-038 Standards committees are compensated monetarily for time nor expenses.

I do not begrudge this, I chose this path.  I do it because I got involved in Standards over 15 years ago, in 2003, when I was employed and my time and expenses were covered, … and when I chose to go out on my own, it didn’t sit well with me to drop my involvement in Standards.  Besides, I enjoy it, and it’s challenging, and it keeps me ‘in the loop’ so to speak.  But I do not get paid to do it.

Here is the portfolio of Standards that the ME-038 Committees look after.

AS 2885.0 General Requirements
AS/NZS 2885.1 Design & Construction
AS/NZS 2885.2 Welding
AS 2885.3 Operations & Maintenance
AS/NZS 2885.4 Subsea Pipelines
AS 2885.5 Pressure Testing
AS/NZS 2885.6 Pipeline Safety Management
AS 3862 FBE Coating
AS 4822 Field Joint Coating
AS/NZS 1518 External Extruded HDPE Coating Systems for Pipe

Another thing the industry has been strongly reminded of since I became Chair of ME-038:– operating pipelines and liquid pipelines.  The past 10 years in the AS 2885 world had been very focussed on high quality and high expectations in the design and construction of new gas pipelines (Part 1)… but in the future, the reality is there is an enormous amount of work going on with liquid pipelines in Australia, and in particular there is a growing need to better address existing, and aging, operating pipelines, gas and liquid, which is covered by Part 3 (and by the new Part 6 as well).  I’m pleased to say that our committees are well-represented in these areas now, and we are well positioned to address these growing issues.