Erin Hart
- Apr 12, 2023
- 3 min read

Pipeline Integrity and Compliance Myth #3: Third-Party Reviews Are for Chumps

Updated: May 10, 2023

Curious about how to avoid fines for lack of compliance with 49 CFR §192, Transportation of Natural and Other Gas by Pipeline, and 49 CFR §195, Transportation of Hazardous Liquids by Pipeline? In this series of posts about pipeline integrity and compliance myths, we explain how to avoid some of the most common mistakes companies make when operating oil and gas pipelines.

The “Eyes Wide Shut” Problem: You’re Doing Things the Way You’ve Always Done Them

Are you ready for compliance myth #3?

“I don’t need a third-party audit of my processes and procedures.”

This is a version of “We don’t need to bounce ideas off of others because we’ve been doing it this way for more than 20 years and we're the experts.” My friend, you’ve drunk your own Kool-Aid and are most likely violating the Code of Federal Regulations.

a lion stalking person sitting at a desk

Here are some of the errors we’ve found (and corrected) when we’ve conducted internal reviews for oil and gas operators. See if you've fallen into one of these compliance traps:

They didn’t understand why a certain task was required to complete a procedure and so left it out entirely.
They thought a task was a relic of the past and wanted to take it out of the procedure, not realizing it was required by code.
They detailed tasks in their procedures that the field staff hadn’t been doing for several years.
Procedures didn’t make any sense and employees couldn’t execute the instructions. Instead of asking someone for clarification, they did it the way that made sense to them.
They weren’t following API 1162 standards for evaluating pipeline anomaly data.
They defined terms incorrectly or not at all.
They applied regulations to themselves they weren’t actually subject to.
They forgot to address huge swaths of the federal code requirements in their procedures.
They wrote requirements into their procedures and made them mandatory when they didn’t need to—boxing themselves in with their own written procedures.

How to Avoid the “Eyes Wide Shut” Problem

Let’s face it, not a lot of folks in your company are interested in making sure your procedures say what they should. You’re probably asking the same small pool of qualified company personnel to review your procedures year after year. Are they suggesting changes or enhancements? Probably. Are they finding everything they should? Probably not, and that's why you need a third-party review.

First, operators have their “day job,” which keeps them busy year round. Conducting annual reviews of all your procedures is time consuming. (See the requirements for gas operators and oil operators for all the details.) The result? The required annual review takes a back seat to other tasks, or worse, it becomes a pencil-whipping exercise.

Second, if you ask the same folks to review the same procedures they did last time and the time before that, they have the same biases and blind spots as before. They likely have the same gaps in knowledge, including what’s changed in the regs since the last review.

Harbour Space University has an interesting article on four of the five biases we all can fall victim to and how to avoid them. The fifth bias–repetition bias–is when people interpret statements as fact just because they’re repeated, even if those statements are not fact. Julia Maser of Colby College explains repetition bias and how it can affect our daily lives.

In short, your reviewers believe they are doing what they can and should, but in reality, they have their eyes wide shut. The way to avoid making this mistake (which the Harbour article mentions as well) is to hire an outside expert to take a fresh look at your procedures and find the gaps. Find an expert who doesn’t have the same biases and whose “day job” IS to review your procedures.