Weekend Reading

This is like a low-level soft opening of a restaurant: Parts 1 and 6 are available now on the Standards website, although I haven’t received the official notification email that I usually get.

The close date for comments is incorrect, and will need to be revised to be August 10 at some stage from Standards.

But if you don’t mind that incorrect bit, and can remember that close date is 10 Aug not 31 Aug, go ahead and download them for some weekend reading. It’s quite possible that they will disappear again next week when they are taken off the site to correct the date.

If that happens and you’d like a copy to review in the meantime, contact me and I’ll get one to you.

Or you can wait until next week when they are re-posted by Standards.

I’m now anticipating further delays overall, and so we are creeping towards a November 2019 publish.


Statistically speaking

There is an old article from November 2017, titled “Keystone’s existing pipeline spills far more than predicted to regulators“.  It was written just after a spill in South Dakota in mid-November last year.

It’s been sitting in my “to read” list since that time – I mean, I’d read it, but I knew I wanted to say something about it.  The note I had beside it was “weird risk management methods in NA”, (NA being North America).

The article exposes that the number of spill incidents on Keystone’s existing pipeline is already quite high, at 3 leaks since it began operation in 2010.  So of course I’m interested in what caused the leaks, but of course the media doesn’t go for that kind of fact-finding, just the sensational side of how much product has spilled.

Still, it’s not good, regardless of the limited reporting; it’s not very good news.

But what I find so interesting is the way risk and ‘chance of leaks’ is portrayed there, probably even by the operator’s own documents:

“Before constructing the pipeline, TransCanada provided a spill risk assessment to regulators that estimated the chance of a leak of more than 50 barrels to be “not more than once every seven to 11 years over the entire length of the pipeline in the United States,” according to its South Dakota operating permit. “


“TransCanada’s spill analysis for Keystone XL, which would cross Montana, South Dakota and Nebraska, estimates 2.2 leaks per decade with half of those at volumes of 3 barrels or less. It estimated that spills exceeding 1,000 barrels would occur at a rate of once per century.”

To me, those paragraphs just don’t mean anything.  Are the leaks caused by material failures, or third party interference, or bad welding, or what?  And what is the operator doing to reduce those (rather high!) expectations of leaks.

In Australia, we estimate (and design for) no leaks.  Over any time frame.

I so much prefer the Australian approach to assessing risk:  we ask, what are the threats to the pipeline, and, what can we do to prevent those threats from eventuating?  And then we ask, have we done enough?  And then we ask again, have we really?

Are we really controlling for those threats? – not just the risky third party hits, but also corrosion and poor operating practise, and land movement, and all the other things that may cause our pipelines to not behave how they are designed to (ie, to keep the product in the pipe).

Focussing on statistics like “2.2 leaks per decade” – um, it seems to me, that doesn’t really help an operator to prevent them.






Confirming Conformance

I remember a situation many years ago, during the boom of the LNG pipelines being built in the mid-2010s, when I was quality manager for a pipeline construction company.  Our purchasing officer was trying to organise a second order of cabling for one of the facilities projects coming up.  His plea to me was valid:

“This vendor gave us crap products last time – they were basically wrong.  And they gave us incredibly poor customer service to resolve it. And yet, they are ISO 9001 certified (ie, following an audited and verified quality process), and they are the lowest price on the bid list.  What do I do?  How can we continue to purchase from a company that obviously does not adhere to its ISO 9001 principles (good quality product, focus on the customer, etc etc)?”

I am sorry to say that I never had a good answer for him.  He was under pressure to award the contract.  We had no recourse – no one to ‘check’ – on the fact that they were not meeting ISO 9001 requirements, and no way to ‘punish’ them.  Because, as big as these projects were to us, they were tiny in the scheme of this cabling company’s order book.

And so, the customer suffers, and the vendor gets the contract.

I bring this up for a couple of reasons:

  1. Victoria is introducing mandatory registration for engineers.  I have mixed feelings about this – but suffice it to say there is plenty of evidence out there that points to registration not making a bean of a difference for competency, and it’s really just an income stream for the registering body.  (On the other hand, the Canadian approach to registration makes being an engineer revered and respected – or at least it did when I was there 20 years ago – and there is (was) an embedded sense of duty to uphold if you’re going to call yourself a (registered) P.Eng in Canada – which leads to a higher level of competency, or so it should).  How is the pipeline industry going to respond to the Victorian requirement?  What do we do with all of the eminently skilled senior members of our community who are not CPEng, and who may be too far along in their career to be interested in the $2k registration + ongoing costs , for less than 5 years of work ahead?
  2. We’re shortly going to publish the new suite of AS 2885.  After 1400+ public comments on the drafts last year, it’s guaranteed that it won’t satisfy everyone in the industry, in a lot of ways.  But like the cabling example above, what do we do if a company is not upholding the requirements of the Standard?  Sure the technical regulators should step in, but in a lot of cases we know they don’t, or can’t effectively.  Adhering to the requirements for Quality (ie ISO 9001) and for Safety (ie AS 2885) benefit the company, and the customer, and the general public – but they tend to be a cost centre, not a profit centre (no “money” is made being safe or of quality – it is saved or costs avoided).  So it’s conceivable that not all requirements are met (shh!).  And what if they aren’t?  What can we do?

In both cases above, we can have a situation where the vendor gets the contract (the registered engineer, the signed document that says yes to meeting AS 2885), and the customer suffers (mistakes are still made, or the standards are not upheld and … boom).

Like for my cable-buying friend, I don’t have the answer for these scenarios.   Except that by virtue of being in the pipeline industry, we have a sense of obligation and duty to our colleagues and to the public, and we wear this with honour, right?

“My reputation in my calling I will honourably guard … I will early and warily strive my uttermost against professional jealousy or the belittling of my colleagues in any field of their labour… I will not henceforward … be privy to the passing of bad workmanship or faulty material in that which concerns my works as an engineer…”

From the Ritual of the Calling of the Engineer, a Canadian tradition for Professional Engineers to recite prior to graduation.




What do you know?

A vexing problem for any knowledge worker (ie, a person whose job involves handling or using information), is the corralling, filing, structuring, retaining and otherwise accessing and using that knowledge and/or information, at the right time, when it’s needed.

There is a lot to that sentence – the ‘organising’ or ‘storage’ of information/knowledge, the ‘using’ of information/knowledge, and the ‘temporaneous-ness’ of it (I just made that up.  I mean timeliness, or, right information, right time).

Right now we’re striving to get six technical pipeline Australian Standards out to the industry in the next 12 months, and that means a lot of information and knowledge to be taken in.  It will be over 1000 pages of important words.

Many of us will skim through the information, try to raise our awareness, do our best.

Some will read thoroughly, question it, nit-pick, and basically help with the next round of improvements.  We love those who give it that detail of attention.

What I know about using these Standards – and many technical documents – is that it is difficult to read it cover-to-cover.  I’ve done that, from a technical editing point of view, but I know I didn’t retain most of the content of what is in there.

The reality is, we tend to learn the contents in-depth when we need to, when we’re faced with interpreting the contents for a particular question or problem at a particular time.

And at that moment, we go to the Standard, looking for a glorious answer to our prickly problem – and how many times do we find that it’s really not just there?  It might be hidden in the words, but there is a gap – gasp – judgement and thinking required to resolve the uncertainty.

This is not easy.  But that’s the beauty of being in the engineering/technical/problem-solving space.

And a lingering problem, in these situations, is where to go for more information, more knowledge.  Where to go for help in interpreting, judging, and deeper thinking about the words on the page.

In 2011, the APIA/APGA produced a “Guide to AS 2885”, which is dozens of pages long, explaining the basics of pipeline engineering and pipeline standards in Australia.  Then there are 77 issue papers appended to the Guide, totalling 400 pages themselves. Fascinating background, but not ‘useful’ unless I specifically have a problem in one of the topics.  I’m currently wading through those 400 pages looking for gems (that elusive ‘glorious’ bit of information).  I also have pages of email trails from this last 5 years of revisions to Part 1/6, and there are certainly some beautiful words in there to be found and brought to light.

We are planning to produce some companion documents to go along with the upcoming publication of Parts 1 and 6.  But I’m conscious of the importance of the information being accessible, and the documents being useful.  That’s the goal with this next round of publications.

Watch this space (well, actually, watch the APGA space, because that’s where they will be published).


Standards Update – June 2018

Here we go with another update as to where the ME-038 Standards are at.

  • AS 4822 Field Joint Coating: Publishing expected imminently
  • AS 2885.0 General Requirements: Currently out for public comment; closes July 31.  Publishing in October-ish.
  • AS 2885.1 Design & Construction: Preparing final draft.  Publishing in October-ish.
  • AS 2885.2 Welding: In styling/editing mode with Standards. Public Comment in a month or so (July-ish).
  • AS 2885.3 Operations & Maintenance: Final touches with the committee; then to Standards for styling/editing.  Public Comment in August/September.
  • AS 2885.4 Subsea: Current; no changes underway.
  • AS 2885.5 Pressure Testing:  committee kick off meeting in late June.
  • AS 2885.6 Pipeline Safety Management: Preparing final draft.  Publishing in October-ish.
  • AS 3862 FBE Coating: Currently being revised by committee.  Public Comment later this year.

And here it is in pictures

status jun 018




Site Specific vs Operational SMSs

In 2018 so far, I’ve facilitated a number of site-specific SMS workshops, required because of new developments near existing pipelines.  In AS 2885 terms, these are the “Land Use Change” and / or “Encroachment” safety management studies.

It strikes me how different these site-specific SMSs are, as compared to the 5-yearly operational ones.

With the operational SMS, third-party activity over the pipeline is a possibility, an imagination, a ‘scenario’ that we try to come up with, for the entire length of the pipeline.  We’re peering at satellite imagery or Google Earth trying to imagine if there’s a situation where a third party will be working near the pipeline.  And we’re reviewing existing operational information, inspection details, and past land access requests and DBYD records, and all that goes into the information gathering for an operational SMS  – it’s arduous and detailed work.

For a site specific SMS, it’s a little different:  we know there will be third party activity around and even over the pipeline – that’s why we’ve convened the workshop.  And we know where – it’s a known, defined location.  So there’s no speculation involved.  We know they are going to be there – and maybe even when.  And we know the characteristics of the pipeline there, at that defined location. We can therefore work closely with the developer to prevent unauthorised access. We can even stipulate to the developer the maximum size of excavator allowed on site for their development – which will, conveniently, equate to the size of excavator that has calculated out to be the one that won’t puncture the pipe.  Win!  (And yes, the developer can ignore it  – or, more probably, the sub-sub-sub contractor who actually does the work might not know about the imposed size limit-  but I’m putting that aside here, that’s about control effectiveness.)

For non-location specific threats like corrosion or poor operations procedures, the operational SMS needs to cover all of the possibilities here again.

But a land use change or encroachment? It’s fair to say that the controls  (cathodic protection, coating checks, operational procedures etc) for those identified non-location specific threats should be in place whether the development proceeds or not.  Sure, it’s worth checking the ILI survey to see if there are defects nearby that should be reviewed for repair/replacement before development proceeds, but corrosion as a threat because of a new development? I’m not sure there’s an argument there, and so it doesn’t need to be discussed at the workshop in depth.  And the proponent of the development is not responsible for corrosion control anyway (except in the case of a development causing interference to the CP system).

The 5-yearly operational safety management studies are long, arduous, deep and philosophical (to a point).  One of the purposes of the operational review is for the pipeline owner, operator and staff responsible for that pipeline to review and update what they know about the pipeline corridor, and what’s changed, and what might change.  It can be very judgement based, and requires all of the calculations for the entire pipeline and deep field knowledge about the entire pipeline including what size of machinery might be working around there.  Due to those uncertainties and the inability to definitely say whether these threats are controlled at a specific location, the risk assessment step comes into play, and then quite often the ALARP process as well.

Site-specific studies for encroachment (work on or near the pipeline) can be much more focussed and laser-eyes on the actual possible threats at that actual location – and hopefully that means that the threats can be judged to be controlled, due to the restrictions that can be placed on the developer.  So for an encroachment SMS for a specific construction activity, I might think there is rarely a need to go into the risk assessment step nor ALARP process.  The goal for encroachment is to do everything we can to control the threat, based on the known information about that particular situation.

Site-specific studies for land use change, where the location classification has increased to a higher consequence outcome should there be an event, will of course require some more work by the pipeline company to recognise the additional consequences and modify the pipeline.  But where the location classification doesn’t change, there’s less to focus on.  All controls should already be in place.

I’ll reiterate though that it is still essential to hold an SMS workshop with the developer as per the AS 2885.6 requirements, early in the development planning.  It is essential.  One of the key purposes of these workshops is to inform the stakeholder (developer) about the requirements to keep the pipeline safe.  This is achieved best in a workshop environment, not via letters or emails.

The recent series of workshop facilitations that I have been doing have not resulted in land use change (change of location classification).  The development was either already in a T1 area, or already had a secondary classification which put it in T1 requirements anyway. Or the protection measures were already in place in anticipation of development. I guess I’ve just been lucky so far, not having a contentious SMS workshop situation (yet).

Unless, perhaps, I have over-simplified this.  I’ll bet my next engagement will be a doozy, and I’ll have to come back here and re-write all this.  Because we always keep learning, don’t we?

And a lingering challenge that I’m aware of is that the developer gets an appropriate document from which they understand the summarised requirements that they need to adhere to.  A big long threat list / spreadsheet or SMS database, or an 80-page report, is probably not going to get the salient points across to an overworked developer who is mostly thinking about his profits.



“Licensee” – or, maybe just “Bob”

The defined term “Licensee” has certainly had a storied history in the AS 2885 suite.  Years ago, we referred to the “Owner” and then later “Operator”. But with changes to corporate structures, and outsourcing of the operations task, and a variety of other issues in the industry, there was a concern that putting the responsibility (ie, costs) on a third-party operator could invite problems if they weren’t given the budget to do a proper job by the ‘owner’ – or whoever puts up the cash.

We on the Committees recognise that building and operating a pipeline safely is not done without incurring costs – however we are not in a position to proportion how those costs are allowed for amongst the variety of commercial entities, ownership arrangements, and joint ventures.

The term “Licensee”, in the Part 0 currently out for public comment, is defined as:

“entity held accountable for the pipeline under relevant legislation”

This tries to cover those pipelines that aren’t licensed per se.  I see now that maybe “Licensee” is a term that may fade away in the next revision, because actually holding a license is irrelevant with this definition.

Note 1 to the definition in Part 0 clarifies:

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

So, we may as well have called the entity “Bob”.

So if “Bob” is the entity held accountable for the pipeline, then “Bob” has all the responsibilities and approval requirements outlined in the suite of AS 2885.

And I guess what’s clear to me now, from discussions amongst users of the Standard, is that we need to reiterate that the Standard can’t tell you exactly who Bob (the entity, the Licensee) is in each case.  There are many different state-based regulations and they are not consistent across the country, and then there’s New Zealand too. The Standard can’t cover legislative issues.  So, the entity that is “Bob” (the Licensee) needs to be worked out with your regulator.

And it should probably be documented somewhere, so that it is clear in the future.

There are two other Notes to the definition:

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

Again, highlighting that the current Licensee (“Who’s Bob now?”) should be documented somewhere in the contract, or submission to regulator, or however the mechanism is enacted for your pipeline.

Note 3: In some contexts the use of Licensee means the person representing the entity, and in some contexts it means the overall entity as defined.

This was alluded to in the previous post, and admittedly, is a technicality that may be hard to get our minds around sometimes (even with my use of “Bob”, that implies a person not a company, which isn’t always the correct context).

The AS 2885 suite of Standards puts a lot of obligations on the Licensee (poor ole Bob).  This is conscious and on purpose – it is so important that our pipelines are kept safe, and that someone (some entity) has overall responsibility for that.

If we didn’t define a Licensee, it might be like a commercial jet being flown without a designated pilot/co-pilot arrangement.  Someone needs to have final and overall responsibility for our very safe assets (which, as has been said a few times by luminaries in the industry, which are very safe, as long as we always remember they are very, very dangerous).



Random Part 0 things

Here’s a list of random notes I have, about interesting things I know about:

  • The definitions of ‘gas’, ‘fluid’ and ‘petroleum’ have been removed from the Defined Terms listing in the new Part 0.  Section 1.2.1 Inclusions describes what the AS 2885 series applies to and lists the types of gas and liquids.  Also deleted are ‘fittings’, ‘pig’ and ‘construction’.
  • ‘Regulatory Authority’ is no longer a defined term; it is now embedded in the definition for “Approval”, by referring to the ‘relevant authority with responsibility to administer legislation relating to pipelines…”
  • Induction bends are not ‘pipe’, they are a ‘component’.
  • Pig launcher/receivers are a pipeline assembly (not ‘pipe’)
  • There is a now a Note 3 to the definition of Licensee, recognising that sometimes the Licensee is the overall entity (“The Licensee is responsible for the safety of the pipeline” (1.3b) ), and sometimes it is a person, which we have now designated as the “Licensee’s representative (“The Licensee’s representative shall approve the following documents (4.4.2) ).
  • The list of “other” documents to be approved (the delegatable ones – that is not a word, delegatable, but, you know what I mean)… the delegatable documents list now includes the procedures listed from Part 3 (Operations), so it is quite an extensive list now.
  • The terms “physical control” and “procedural control” are usually used very closely together when we do our safety management work.  In Part 0 though, because of the alphabet, they are ten listings apart.  We tried to combine them under controls or measures – there are long strings of email correspondence on this – but we couldn’t make it work within Standards’ template and how we wanted it to look.  So, well, sorry about that.
  • Read the Basis of the series (Section 1.3).  It’s quite good information, and it lists the principles behind our safe hydrocarbon pipeline system in Australia.  We should all, always, strive to work to these principles, every day.

To scope or not to scope…

The scope section of Part 0 has been updated to include the nomenclature of “AS (/NZS)” to recognise that not all parts of the AS 2885 suite are a joint standard with New Zealand.

It also now utilises the “Pipeline System” in place of “Pipeline”, where applicable, to recognise that we design, construct and operate a whole system, not just some round steel in the ground.

Mostly the text has just been tidied up and clarified.

What doesn’t show up in the screenshots below is the ‘small caps’ now used throughout the AS 2885 series, to draw attention to where a term is a Defined Term.

Get your copy of the Public Comment draft from standards.org.au.  Don’t rely on these screenshots for your review.

(The public comment draft doesn’t include strikethrough markups, unfortunately; …I’ve done this semi-manually.  I won’t be providing marked-up versions of every section of Part 0,  just those that are easier to explain via markups):



Figure 1.1 has been significantly revised to convey the overview scope of AS 2885 more clearly.

Note that the scope figure in Part 1 (Design and Construction) provides more detail on the centre section inclusions; this figure is in Part 0 which is just depicting a scope overview.




It’s less than 30 pages…

Part 0 is only 22 pages long.  It’s thin enough to be stapled together by a normal stapler (for those of us old-school, who still prefer the printed version for review).

2018-06-01 16.25.58

And if you’re new-school, reviewing online, you will notice that the pdf onscreen version has hyperlinks to referenced sections  – that’s a nice improvement.  But before I use them, I need to know how to get back to the spot I was reading before using the hyperlink….  Suggestions on how to do that are welcome below or via an email to me.




Anyway, thirty pages is a breath of fresh air, compared to the hundreds of pages that make up Parts 1 and 6, coming out for final review in a few weeks.

So we’ll spend the next couple of weeks looking at Part 0.  Read along with me on the journey…

2018-06-01 16.27.18

Standards Australia is now generally adopting the ISO approach to structure and formatting.  You’ll notice that in the definitions section, it looks different to what previous definitions looked like.  And in the table of contents, we can see that where Appendix A used to be the list of references, that is no longer the structure – references are now listed in 1.4 (Normative references) and / or the Bibliography (non-normative).

The Foreword has been done away with, page “v” is now an Introduction instead – containing Foreword-like information.

Next week we’ll get into some of the nitty gritty of the actual words.