1155 North State Street, Suite 609, Bellingham, WA 98225 Phone 360-543-5686 Fax 360-543-0978 http://pipelinesafetytrust.org
Comments on API Recommended Practice 1162
Public Awareness Programs for Pipeline Operators
The Pipeline Safety Trust appreciates this opportunity to provide our observations on API recommended practice (RP) 1162. The implementation of this RP was a major undertaking for the industry, and provided a good step forward in developing communication with those stakeholders outside of the industry and regulators most affected by, and most likely to affect, pipeline safety. As this RP recognizes continuous improvement of such practices is essential so we are pleased that the RP is being reviewed, and hope you will consider our ideas for strengthening these recommended practices.
1. The Basic Goal of the RP is Flawed
The basic goal of RP 1162 is to “enhance public environmental and safety property protection through increased public 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.
2. Public Awareness of Pipelines Objective
Much of the point behind one of the two major objectives of the RP seems to be based on the belief that if people understood that we all want the products pipelines transport, that pipelines are relatively safe, and that pipeline operators take good care of their pipelines and are ready in case something happens they will be more apt to act in a safe manner around pipelines. While this statement is certainly true, the RP provides no evidence that such a basic message leads to the desired behavior change, or even that the basic message was ever tested against equally true messages for effectiveness. Perhaps a basic awareness message such as – “There are over 2 million miles of pipelines in this country, and on average there is a significant pipeline incident every day somewhere, and a person is injured or killed every 5 or 6 days” – would be more effective at increasing awareness and changing desired behaviors? Was any research done to compare messages to see which would actually be best to increase awareness and lead to safer behaviors?
3. Section 2.2 - Overview for Meeting Public Awareness Objectives
This section describes the four major stakeholder groups that the RP focuses on, and describes the relevant information that the program should communicate. Again, for this expensive effort to be of value the objectives need to be based on changing behavior, not just communicating information. For instance, in this section the information listed to be provided to “local public officials” is a subset of the same information to be provided to the “affected public.” If the real objective was meaningful behavior change then this section ought to provide some guidance in what outcomes are desired from these different groups. 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
Inclusion of such behavior change objectives for each target group would help target the message more specifically to the different groups.
4. Important Considerations Missed
The RP is generally lacking enough detail for a company to institute a thorough communication plan. More information about designing and customizing the message for better success, identifying barriers to success, choosing delivery methods, and meaningful evaluation are needed. The recent 7 step communication process (Appendix F) of the Pipelines and Informed Planning Alliance effort does a good basic job of providing an overview of the complete process. Texas Excavation Safety System example.
5. Need for Greater Transparency in Relevant Incident Reporting
The RP never recommends that the operator discuss the risks and safety record associated with its operations with the intended audiences. These discussions are to be couched in terms of the safety record of the industry as a whole. In reality we believe that a thinking stakeholder would be interested in the actual hazards and safety record of the pipeline that runs through their community, and the sharing of that information will lend credibility and respect to the message. Side stepping this issue causes doubt for the entire message. The public has begun to expect accountability with the advent of required annual reports on the quality of their drinking water, toxic chemicals released into their air, or even comparative test results for the schools they send their children to. Pipeline operators would be well served to provide the specifics of their safety results as well, since for the vast majority of companies their safety records will speak well of their efforts. For the companies whose safety record may be of concern, disclosing that record will hopefully provide another incentive for improvement, and help prove to the public the company’s commitment to improvement.
6. Section 2.4.7 (Operator Employee Participation)
Although the RP remarks that “informed employees …can play an important role in promoting pipeline awareness,” it doesn’t seem to define clearly any meaningful suggestions in training company personnel and contractors about its Public Awareness Program and how they are important to its success. It is well understood that one negative experience with a company employee or contractor can undermine previous community outreach activities. For that reason it seems at a minimum all employees and contractors that have contact with any of the targeted stakeholders should receive some basic training in the companies public awareness program.
7. Section 8.4.3 (Measure 3—Desired Behaviors by the Intended Stakeholder Audience)
Assessing whether the Public Awareness Program successfully drove other behaviors should not be relegated to a supplementary evaluation, as it currently is. Changing behaviors so that pipeline operations are safer should be the prime objective of an operator’s program, and the measurement of those behavior changes should be the prime method of evaluation.
8. Transparency in Awareness Programs and Effectiveness Evaluations
Individual companies, API, or PHMSA should make individual programs available to the public, and more importantly the effectiveness evaluations and proposed changes based on those evaluations should be public.
9. Development of RP is Flawed Process
According to the Foreword (page iii), the intended audiences were not represented in the development of RP 1162, though they were allowed to provide “feedback.” The omission of representatives from these audiences from the voting committee reduces the depth of understanding the RP could have had, and undercuts the credibility of the recommended actions.
The public awareness program regulations--49 CFR § 192.616 and 49 CRF § 195.440—mandate that operators comply with RP 1162. In essence, this amounts to the drafting of federal regulations without the equal participation of the stakeholders the regulations are meant to involve. With non-technical subject matter, such as this RP deals with, it is difficult to justify excluding the intended audiences from the process and allowing the regulated industries to write their own rules.