A Hierarchy of Good Intentions

Many parents will be at least vaguely aware of Piaget’s theory of moral development in children.  Kids up to about age 10 tend to think that right and wrong are defined by rules and punishment, regardless of context.  Older children begin to appreciate that rules might not be absolute but are made by people to achieve a broader purpose, and with this realisation they are better able to engage in moral reasoning for themselves.

An emerging theme from some of the Energy Pipelines CRC work on the sociology of safety is that there is a somewhat parallel hierarchy in the approach of engineers to safety:

Compliance – Quality – Integrity – Safety

At the most basic level, we all know that we need to comply with the rules.  In this industry the rules are mostly set out in AS 2885 and other standards.  However seeking to achieve compliance purely by following the rules without thinking about the broader safety objective is not necessarily the best way to achieve that objective.  (Standards like AS 2885 are almost entirely about safety, even though that the safety objective is mostly tacit except in the context of safety management studies.)

The next step is thinking about quality.  Quality assurance programs go beyond mere black-letter compliance with a standard but still miss the ultimate goal by a wide margin.

Integrity is a worthy objective and a huge proportion of pipeline operating companies’ efforts are devoted to monitoring and maintaining pipeline integrity.  But thinking only of integrity without the broader context of safety yet again falls short.  If you think I’m splitting hairs, let me point out that PG&E prior to San Bruno had a large pipeline integrity management program.  However it was divorced from any thought of the consequences of failure and the outcome is well known.

I believe that explicit consideration of safety, as required by an AS 2885 safety management study, is the most mature and effective way to manage it.  Stated like that it sounds trite, except for the many instances where compliance, quality or integrity are used as proxies instead of safety.

Of course life is nice and simple if you only have to comply with the rules and not think more broadly, but taking such a simplistic approach can be viewed as unprofessional – professionals are paid to think.

It can become complicated though.  I am currently working with a client who has some pipelines for which the hydrostatic pressure test certificates have been lost through administrative errors (ie. a pile of “old” paper was taken to the tip to save on document storage costs, a sadly common story).  AS 2885 is unambiguous that a pipeline must have a valid hydrotest.  If there is no documentation or other evidence (eg. a declaration from the testing engineer that yes, he clearly remembers successfully testing that pipeline 20 years ago) then it is very likely that a re-test is required.  That’s applying the rules.  On the other hand, in a safety management study the risk evaluation showed that there is minimal risk associated with failure of these pipelines due to lack of strength.  These particular lines are in a remote area far from any people and operate at a small fraction of their MAOP except on rare and brief occasions.  Both likelihood and consequences of failure are small so the risk is very low.  If there wasn’t a rule it might be hard to justify re-testing them.  Making the decision to re-test has in fact been made more difficult by thinking more broadly about safety.

I seem to have almost given a counter-example to the point I want to make:  Even if it gets complicated the best way to achieve safety is to address it and understand it explicitly, not via proxies such as compliance, quality or integrity.  Those lower steps on the hierarchy are necessary tools but should never be regarded as the end objective.

[The EPCRC work I referred to includes the Intergenerational Study, the Safety in Design study and a forthcoming report on sociological analysis of the San Bruno disaster.  All are (or will be) available to members (or employees of members) of the APIA Research and Standards Committee.  This excellent work was done by Jan Hayes and Sarah Maslen of the sociology department at ANU in association with the EPCRC.

Google will reveal any amount of information on Piaget’s theory of moral development but there is a nice concise summary here.]

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3 Responses to A Hierarchy of Good Intentions

  1. Anonymous says:

    HI Peter,

    Great thought piece. I think you have got to the nub of what it means to be a professional pipeline engineering: thinking and perspective to achieve genuine safety. Great stuff. I think there is scope for a more extended discussion within the industry and among engineers.

  2. Susan J says:

    “professionals are paid to think” – what a profound statement. In these days of rush-rush engineering, and the just-get-it-done-today approach, it is important for all of us to take a step back and do an appropriate amount of thinking. Not easy sometimes, but … it’s what we get paid for. Thank you Peter for an as-always considered, intelligent and thought-provoking post.

  3. petertuft says:

    Oops, on originally posting this I forgot to acknowledge the authors of the work on which my thoughts here were based – now added to the end of the post. Thanks to Jan Hayes and Sarah Maslen.

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