Revisions to Standards

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APGA Webinar 2 (Dec2020): Overview of Australian Standards: 45mins webinar video - Presented by Susan Jaques.

Introduction Presentation Slides from 2019 Launch : Peter Tuft's slides (March 2019)

Does release of Part 6 trigger an "immediate" SMS requirement, or does the licensee continue to meet its current 5-yearly obligation?

(James Czornohalan) This is probably a question for the regulators, but the regulators in the room {for the launch in March 2019} from SA and QLD agreed that this did not trigger new SMS's. Although they expect any SMS to be done to Part 6 in future when they become due.

Is there a plan to integrate the APGA COP for HDPE pipelines with the AS2885 suite, as many elements of AS2885 are applicable, notwithstanding materials.

(James Czornohalan) Not at this stage. The ultimate plan for the HDPE CoP should be, in my opinion, be to become a Standard itself, but that is a question for that committee.

What was impetus to reviewing the 2012 version, by starting the process so soon in 2013?

(Peter Tuft) There was no single major issue demanding revision, but people inside the Committee are always aware of things that need improving. There is already a long list of things to fix in the next revision of Part 1, and some possible clarifications to Part 6. Another important point is that the 2012 revision was not the result of a serious technical review as its main objective was harmonisation with other Parts of the AS 2885 series. Also, Standards Australia require that standards be reviewed about every 5 years anyway, and we knew it was going to be a long process so 2013 seemed the right time to start.

Could testing of pipe be mandated through the Standard to ensure that we build up our knowledge base? (i.e on projects larger than $20 million)

See General / Admin

Given the number of comments from Public Comment, shouldn't comments that were rejected by the Committee require feedback to the commenter for an explanation?

(Peter Tuft) This is a matter for Standards Australia. I agree that there should at least be the option to provide feedback, particularly for comments that are rejected.

(Susan Jaques) There is currently no mechanism for this kind of feedback with Standards Australia. So it would be a massive manual effort to ensure consistency and clarity in the responses. Also, the committee doesn't officially have access to the contact details of the commenters, that is considered private information by Standards Australia. In many cases we know the commenter, but in several we don't have contact information.

Should Part 6 be called Pipeline ‘System’ Management by definition?

(Peter Tuft) No, it refers to Safety, so the title is correct.

(Susan Jaques) Being pedantic, ok yes, perhaps Part 6 should be titled Pipeline System Safety Management, for consistency with the defined term for Pipeline System (there is no defined term for pipeline).

Is there any transition period like 30 days for new AS2885 parts published to be effective? Or is it effective from the publish date? Asking because the US codes have a transition period normally from date of publish. When a new revision is published, at what point, or when does it apply?

(Susan Jaques) The Parts are effective as soon as they are published, but it’s also a discussion with the technical regulator, who may give some leeway. The committee gets this question a lot, but we are not sure why you wouldn’t start using the new Parts right away, so we’re looking for examples where it’s not easy to.

(Peter Tuft) I think the question has a theoretical answer and a practical answer. The theoretical answer is for the regulators rather than us. It may vary depending on whether the legislation/regulations refer to a specific revision of the Standard or just AS 2885 in general. But the practical answer is: Anyone who does not apply the new version ASAP is leaving themselves wide open if anything were to go wrong and non-compliance with something new in the Standard is a contributory factor (not likely, but why take the risk?).

It’s hard to think of anything that does not need to be applied immediately on publication. Since the public comment drafts have been out for ages anyone who is sensible will have been more-or-less working to those for some time already. I’ve mentioned previously that prior to the 2007 revision of Part 1 people were explicitly working to and referencing DR04561 (the public comment draft) for over two years, from its publication in December 2004 until March 2007 when AS 2885.1:2007 was published.

Explain the difference between "should" and "shall" in Standards, and the AS2885 committee principles on the use of should vs shall?

Ideally, a Standard should(!) never need to say "should". It would be nice and clear if all requirements were mandatory.

But the real world is not as neat as that and discretion is often required. Nevertheless, we minimise the use of "should" and prefer "shall" unless there is good reason to allow discretion.

The committee members make an effort to consider each instance of "should" and consider whether it can be changed to "shall". This is not something done lightly. It will be important to consider carefully whether there are any situations in which complying with a "shall" statement is unreasonable or impossible. Where "should" is used correctly (ie. it is intended to allow discretion) we do not need to be concerned about whether the recommended requirement is reasonable in all circumstances. Nor is there any need to write qualifying statements about "subject to further assessment", "shall be considered", etc. All that is implied by the term "should".