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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.