Date: 11/30/09RE: Comments on Draft 17 of API RP 1162 – Public Awareness Programs for Pipeline Operators
First of all the Pipeline Safety Trust would like to thank API for including us in the review of this most current draft of RP 1162, and for interviewing us as part of the process to develop this draft.
At this stage we have not attempted to do a line-by-line review of this document or specific comparison with the current recommended practice. This remains an industry recommended practice and our review of it has been limited by time and staff constraints. If in the future PHMSA or Congress initiates a process to incorporate these changes into federal regulations we will provide a much more in depth review.
• Focus on Core Safety Messages – We agree with the new focus on core safety messages, especially moving the “pipeline purpose and reliability” message to the enhancements section. We agree that too many messages may detract from the overall purpose, and in some cases cloud the more important safety messages. As we noted in our earlier comments last spring we believe that often the “pipeline purpose and reliability” message took precedence over the higher priority safety messages. While it is understandable that the industry is proud of its purpose and safety record, too much emphasis on this message may send a mixed message that pipelines are already so safe that there really is no reason to pay attention to the other, often higher priority messages contained in the awareness program. It should be noted in the enhancement section to guard against allowing the “pipeline purpose and reliability” message to undermine efforts to get the targeted audience to pay attention to the higher priority safety messages.
• Greater Alignment of Requirements to Allow Collaborative Efforts – We support the alignment of requirements to produce greater efficiency and cost savings, but caution needs to be taken that collaborative efforts do not undermine the effective delivery of safety messages. We find no such cautionary details in the draft RP and ask that such language be added. We have reviewed many collaborative efforts delivered by single vendors on behalf on many companies and have found many of these efforts so generic that they present new barriers to getting the message across. If in an effort to make the delivery method fit many different company’s audiences it becomes difficult for the targeted audience to understand the information is meant for them, then the benefits of cost saving and efficiency has undermined message delivery.
• Elimination of Impractical Provisions – We strongly disagree with the elimination of measurement of desired behaviors by the intended stakeholder audiences for measurement of effectiveness measurement. This measurement is not impractical and in many ways is the only real measurement that matters. We include here a redraft of our comments on this issue from last spring.
The Basic Goal of the RP is Flawed
The basic goal of RP 1162 is to “help protect people, property and the environment through increased stakeholder awareness and knowledge.” Yet nowhere in the RP is any information provided that supports the premise that greater awareness and knowledge makes things safer. To the contrary, many recent studies in behavior change have shown that increased knowledge and awareness of information does little to actually change behaviors. If the actual goal is to really enhance public safety and reduce environmental and private property damage, then the goal should be to change behaviors that will actually lead to safer conditions. Since the basic premise of the RP is flawed, much of the emphasis on producing awareness materials and measuring the distribution of those materials and the associated change in knowledge is meaningless. The basic goal of the RP needs to be changed to something such as:
The overall goal of the pipeline operator’s Public Awareness Program is to produce programs that lead to enlightened behavior changes in the target audiences that increase public safety and reduce environmental and private property damage.
Again, for this expensive effort to be of value the objectives need to be based on changing behavior, not just communicating information. For instance, section 9.3.3 – “Achieving Results” spells out one very measurable change in behavior that could demonstrate “bottom-line results.” Each audience section ought to provide some guidance in what outcomes are desired from these specific groups and how they might be measured. Here is an example of what some desired behaviors for “local public officials” might include:
• Inclusion of damage prevention materials at the time permits are granted
• Proof of the use of One Call during compliance checks on excavation permits
• Consideration of the PIPA recommended practices
• Requirement and budget for local emergency responders to get pipeline response training
• Reduction in the number of damages caused by local government employees or contractors
For excavators if one of the desired behaviors is greater use of One Call it would seem that after a mass communication effort it would be relatively easy to determine if the use of the One Call system increased by some percentage.
Inclusion of such behavior change objectives for each target audience would help provide meaningful effectiveness measurement, as well as ensuring that the whole effort has some real “bottom-line results.” We ask that the elimination of the measurement of desired behaviors be rethought, and that the entire RP be realigned to measure exactly that.
It is our understanding that PHMSA will, for the first time, be undertaking some evaluation of effectiveness of operator’s programs in 2010. The ongoing measurement of effectiveness and the requirement of continuous improvement are such foundational parts of this program that it may make sense for the API to delay the release of this new version of RP 1162 until findings from that evaluation effort are known.
The use of “should” and “may” – We must admit that we are always confused by the use of the word “requirements” when reading a recommended practice. It becomes even more confusing when a recommended practice then gets incorporated into regulations. There are many, many uses of the word “should” in this draft where we believe the action needs to be required, yet the definition of “should” makes it optional. It is unclear what really is required to meet the recommended practice and what is optional. This would become even more problematic if eventually this new version of the RP is moved toward incorporation as regulation.
Basis for various determinations – We found no references that could be used to help understand how various parts of the RP, e.g., delivery frequencies, awareness equating to behavior change, etc. were determined. The overview of proposed changes contained a footnote that appeared to reference such studies, but no actual references were provided in the RP. It would be good if all studies, surveys, experts, etc. were referenced in an appendix.
Thank you again for this opportunity to comment on this important practice. This has been a huge undertaking by the industry and we fully expect that what necessarily started, as an effort to get information into the right people’s hands, will evolve as time goes on into a more targeted effort to produce real safety change. We share your continuing desire for increased safety and stand ready to work with the industry wherever that desire leads us.