Directed Questions to ASTM and ASME

Vanessa Allen Sutherland: [0:02] Because the SDOs have such different models, I think we heard people alluding to this morning, yes, we believe that there are ways to change. Some SDOs already make their standards available for free online, like NFPA. [0:17] For those who don't make their standards available online, have you discussed what possible proposals or solutions you think would be reasonable? Whether that's online but read-only--I think we heard it this morning on the second panel--or read-only but printable, or something of that sort?

[0:39] Have you discussed and at least contemplated what might be a reasonable middle ground to implement section 24, given what we've heard today and given your varied business models?

[0:58] Not to put Jeff on the spot, but he's standing up.

Jeff Grove: [1:04] Yes, I think it's fair to say most SDOs are really looking at this issue. I mentioned earlier, we've taken one incremental step to provide access, free, at no cost, to standard during rulemakings. We've already moved in this direction more than we ever have in the past. [1:25] I would say yes, we are looking at this issue. I can't give you a timeline, though, for when you might see more SDOs move in the direction that NFPA has. It's just a delicate balance and there's a lot of unknowns, how it impacts our model. We're very interested in getting to the end of it, but we're not there.
Joseph Wendler: [1:48] Yeah, Joe Wendler from ASME. Similar, we've made one of our standards available during the rulemaking process, using the real read software. I don't know what data we got from that, saying how many people downloaded it, did that impact our sales down the road? I don't think we have that data. [2:04] I think we're a little hesitant to just go full steam ahead because, once you turn that switch, you're going to have to do that for multiple standards, multiple agencies and it's hard to go backwards once you've made that step.

[2:16] We're actually interested in getting data to see how that would potentially impact our model. We just can't make that step without that data.

Vanessa Allen Sutherland: [2:25] Let's ask the opposite question, which is we heard this morning that IBR, I think we heard both from [indecipherable 02:34] and NIST that IBR has been successful over the last several years following the NTTA, and certainly we've been incorporating at PHMSA by reference since the '70s. [2:47] Maybe we should discuss what do people see the impacts being if the government, if PHMSA in this particular instance, started writing its own unique standards? Because, what I think we heard, and I don't want to mischaracterize.

[3:01] We're in a fact-finding mode at PHMSA. I think I heard from the panels that that may not be the best solution come January if we haven't reached some form of compromise. I wonder if anyone has any other thoughts about PHMSA writing its own government unique standards, the impact that that would have in general.

[3:22] We know what it would do to the rulemaking timeline. I think it would be longer, certainly. But, overall, we heard this morning that there's an interest in keeping up with technology, getting broad consensus when these standards are made, representative views and pushing safety forward.

[3:39] If we were going to take that on, absent being able to reach a resolution as of January, what are thoughts on what that might mean to the SDOs and, ultimately, to some of the safety organizations that are here?

Neil Eisner: [3:52] As a variation to that, what about PHMSA writing a more general standard saying, "One way of complying with the standard is one of the SDO standards or an alternative means of compliance subject to approval by the administrator." [silence] [4:07]
Man 2: [4:15] I just got to tell you from one of my clients, since they've elected to sue the federal government for lack of pipeline safety in their state, which wasn't my necessarily recommendation. I just tell them who's the truth and who's not telling the truth. [4:28] What my perspective was, was that was a vote of confidence in the PHMSA technical state capabilities given the lack of technical pipeline capabilities in that particular state. From a technical perspective, and through my many years of interaction with various groups and PHMSA, PHMSA has the technical capabilities and I wouldn't sell them short.

[4:50] The problem is there's a lot of resource demand on their time. If you're going to propose something or an alternate engineering approach, I think from a public perspective and my feedback from my clients is it would have to be very definitive.

[5:05] Because if you leave it to the choice of the pipeline operator, you're kind of in the do-loop that started this process. It's selectively interpreted. That's an honest opinion from my perspective. Thank you.

Jeannie Layson: [5:17] Thank you. We've got a question that's...

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