Energy Worldnet (EWN) hosted the first-ever Compliance Leadership Forum (CLF)—a peer-to-peer space designed for candid, practical conversations about pipeline compliance and safety. Hosted by James Cross (Chief Experience Officer, EWN), the session brought together more than 150 years of combined experience from former state and federal regulators and industry leaders.
Meet the panel
- Kevin Speicher, Senior Regulatory Advisor, EWN; former Chief of Pipeline Safety, New York State Department of Public Service
- Steve Allen, former Director of Pipeline Safety, State of Indiana; longtime PSMS advocate and former EWN executive
- Alan Mayberry, former PHMSA Associate Administrator, now with Jana and serving on boards focused on advanced risk and geohazards
- Jeff Wiese, former PHMSA Associate Administrator; former offshore operations leader; longtime safety management advocate
The tone was clear from the start: no judgment, anonymous questions, and a focus on what operators can actually do next.
Discussion & Key Takeaways
1) PHMSA’s final rule on class location changes: a new, permanent pathway
Kevin Speicher provided a high-level overview of PHMSA’s final rule addressing class location changes for gas transmission lines as population density increases along existing rights-of-way.
Historically, when a segment shifted (for example, Class 1 to Class 3), operators often faced limited options—even if the pipe was in good condition—such as:
- lowering operating pressure,
- performing pressure tests, or
- replacing pipe.
Kevin explained that the final rule creates a clear, permanent pathway for certain Class 3 segments to confirm or restore MAOP using integrity management, rather than relying on the special permit process.
Panelists Alan Mayberry and Jeff Weiss added context: many of the rule’s requirements reflect the special permit conditions PHMSA had been reviewing for years—so codifying this approach helps reduce repeated special permit workload while creating a consistent compliance path.
Practical note from the panel: expect inspection focus early. If you use the new pathway, be ready to show eligibility, documentation, and decision logic.
As Jeff put it: Have your ducks in a row.
2) Administration changes at PHMSA: what operators should do
The group discussed how administration transitions can shift priorities, timelines, and rulemaking strategy—without changing the core mission: safety.
Key guidance:
- Build relationships before “game day.” Jeff emphasized getting to know PHMSA regional offices before an incident. The same goes for emergency responders.
- Information is currency. Alan noted that rapid, accurate information flow matters—especially during issues that escalate quickly.
- State-federal relationships remain critical. Steve underscored that collaboration between PHMSA and state pipeline safety programs has historically stayed strong, even through leadership changes.
3) Contractor OQ: The operator is still responsible
A major portion of the questions centered on Operator Qualification (OQ) and contractor work.
Kevin’s core point: “Operator” is the keyword in OQ. From a regulatory standpoint, contractor personnel performing covered tasks are effectively treated the same as operator personnel—meaning the operator owns the compliance outcome.
The panel discussed:
- the need for documented OQ equivalency where contractors use different programs,
- ensuring qualifications align to the operator’s procedures and equipment, and
- The reality that many workforces are now heavily contractor-based—making partnership essential, but responsibility unchanged.
Steve added a PSMS lens: contractors must be included in safety management thinking. He cited a hard truth often echoed after major incidents: an operator is only as strong as their weakest contractor.
4) Mutual aid during emergencies: plan early, document everything
Mutual aid questions focused on how to remain compliant when additional crews arrive during storms, flooding, or other major events.
Kevin’s advice was direct:
- Identify likely covered tasks in mutual aid scenarios
- Confirm qualification or equivalency before the event, when possible
- Document the process—because “if it isn’t documented, it didn’t happen”
The panel acknowledged the reality of emergency chaos, and noted that PHMSA has historically issued enforcement discretion notices in some disaster scenarios (especially after hurricanes) to reduce administrative burden—but the guidance was clear: don’t count on it. Prepare as if you won’t get it.
5) PSMS for small and municipal operators: start, scale, and use the resources
Steve addressed PSMS adoption following PHMSA’s recent focus and industry updates. The headline: PSMS is scalable, but smaller operators often face real resourcing challenges.
His guidance for small and municipal operators:
- leverage APGA resources and leadership,
- track the forthcoming RP 1173 (2nd edition) guidance, including a small-operator annex,
- and most importantly: start.
“You don’t have to be great to start—but you do have to start to be great.”
6) Who has the final say in the field? Safety culture wins
A common field question: when a qualified employee and a supervisor disagree, who has the final say?
The panel aligned quickly:
- Supervisors may hold decision authority,
- But a strong safety culture requires stop work authority and psychological safety for employees to raise concerns.
- Team training and organizational dynamics matter—especially in preventing the kind of missed signals seen in historical incidents.
Speed Round Highlights
To close, each panelist answered a rapid-fire question posed by host, James Cross:
- Biggest threat to pipeline safety (Alan Mayberry): being “information rich but insight starved”—operators must know their systems and operating environments and continuously reassess assumptions.
- Owning your OQ program (Kevin Speicher): ensure people can perform tasks safely, recognize abnormal operating conditions, and match qualification to real procedures/equipment—because enforcement lands on the operator.
- Gas leaks and evacuation protocols (Steve Allen): the industry needs clearer trigger points, decision authority, and guidance so field techs know exactly when evacuation is required.
- Compliance vs. safety (Jeff Wiese): Compliance is the baseline “price of admission,” but safety performance improves faster and deeper through safety management systems.
What’s next
EWN will continue the CLF series through follow-up Q&A, newsletters, and future events—including a live CLF session at the AGA Operations Conference in Tampa (April).
James wrapped up the session, "until next time - stay safe, and keep doing the good work."