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Many regulators including PHMSA are incorporating consensus standards into the Code of Federal Regulations (CFR). The goal is to strengthen and streamline the code, be less prescriptive and allow for performance to drive how regulations are met. National consensus standards can carry the equivalent weight of law when incorporated by reference into the CFR. The intent is to ensure standards support the safe design, construction, operation, maintenance and repair of pipelines. Consensus Standards constantly need new scientific information and knowledge to be effective and relevant. They are continually reviewed and upgraded by committees of engineers and other technical experts.
Collaborative research targeting consensus standards will feed new knowledge into the process of keeping standards relevant to their purpose. The PHMSA program is funding this related research to strengthen their scope and to expand their applicability. Significant time and resources are consumed reaching consensus on a research strategy at R&D forums and other stakeholder events. Given this, it’s imperative that knowledge from the research is transferred to sustain Standards Developing Organizations (SDOs). PHMSA is working diligently to measuring the research benefit of projects addressing standards while providing knowledge transfer to the standards-development process.
To ensure success with this research program objective, PHMSA and the Pipeline Standards-Developing Organizations Coordinating Council (PSDOCC) entered a Memorandum of Agreement (MOA). The MOA is improving cooperation and coordination between "the Parties" to simplify a more effective and efficient integration of pipeline safety research and development results into the development and revision of voluntary consensus technical standards. The systematic process described in the MOA is critical to ensure knowledge from pipeline safety research is transferred to end users.
In 2007 PHMSA issued the first data call to relevant SDOs about how the collaborative research with industry is impacting their standards. This was the first time PHMSA contacted SDOs in this capacity and in line with actions described in the MOA. It will take multiple iterations working with SDOs to standardize their responses to these data calls so the public can understand the true impact.
PHMSA will contact relevant SDOs annually and capture the current status or final impact of that research addressing their standards. Many SDOs revise standards on a three or five year frequency so it could take multiple years to register the final and desired impact "Standard Revised." In addition, PHMSA and the PSDOCC must work harder to share the research with the SDO committees to ensure the results are factored when revising consensus standards.
The goal through coordination is to refine future SDO responses down to the following three:
- The research results will be forwarded to committee officers for use in revising the standard.
(Meaning no word yet on the impact but the committee should address this when reconvening)
- The research was used in part to revise this standard.
(Meaning the committee reviewed the research results and it was used in part to revise the standard)
- The research was not used to revise this standard.
(Meaning the committee reviewed the research results and it was decided that it would not be used to revise the standard)
The following section documents the program success in strengthening consensus standards.
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