Energy Worldnet (EWN) hosted the 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.
Compliance Leadership Forum: Discussion & Key Takeaways
RP 1173: evolutionary, not revolutionary
Steve Allen gave a progress update on the rewrite of API RP 1173, the industry's PSMS standard. The working group has cleared roughly 77% of comments from the ballot and is now moving into the addendums covering process safety, small operator implementation, and public engagement.
Jeff Wiese added context on the standards process itself: API is the only major trade group that follows the formal ANSI process for developing a national standard, which means every comment gets addressed and the whole process is publicly available—slow, but rigorous.
Key takeaway: don't expect major surprises. No new shall statements, no removed requirements—just clarifications and refinements. A published second edition is targeted for late Q3 or early Q4.
Alongside RP 1173, RP 1186 is developing leading and lagging performance metrics to help operators gauge whether their PSMS programs are actually working—nearly 200 candidate KPIs are already on the table.
A new leader at PHMSA: what it means for operators
The panel discussed PHMSA's newly named Associate Administrator, Tom Correll. .
Alan Mayberry and Jeff Wiese, who've both known Correll. for years, described him as "an engineer's engineer"—strong technical grounding in gas transmission, with a learning curve ahead on liquids and gas distribution, plus the stakeholder and political dynamics that come with the role.
Practical note: both panelists reached out directly to offer support during the transition. As Jeff put it, working the Congress and the administration is "the stuff that raises your blood pressure"—technical competence alone doesn't prepare you for it.
Engineering Critical Assessments: a good rule, but bring your regulator with you
A newly released NPRM on engineering critical assessments (ECAs) prompted real-time reaction from the panel.
Alan Mayberry called it a positive step—current code requirements around anomalies like dents with metal loss are prescriptive, and the ability to use modern assessment methods (like finite element analysis) is overdue. The catch: it demands real technical competence, both from operators and from the regulators reviewing the results.
The panel's guidance:
Educate your regulator early—don't wait until the analysis is complete to loop them in. Do the work well. As Jeff Wiese noted, if there's ever an accident, an NTSB or regulator review will scrutinize the ECA closely. Kevin Speicher added the state-level angle: technical reviews like this take states longer to work through, so engage them as early as possible.
Multi-state OQ compliance: make the program your own
One of the most detailed exchanges addressed a familiar pain point—staying compliant across states with different OQ requirements.
Kevin Speicher walked through how states like Connecticut and New York have gone beyond the federal baseline:
eliminated the old four-part test, made AOC questions critical (missing one means failing the evaluation), addressed span of control (New York left it to the operator with documentation; Connecticut capped it at one-to-one), and added a required OQ effectiveness review.
Key takeaway: enhanced state requirements generally apply to intrastate operators. Interstate operators still fall under 49 CFR 192's four-part test, though state damage prevention laws (like warning tape requirements) can still apply.
The panel's advice for multi-state contractors:
Open communication channels with clients, operators, and regulators. Lean on resources like the Distribution Contractors Association and NAPSR's state compendium. Build your OQ program around your actual equipment and procedures—not an off-the-shelf template you can't modify.
Regulator's Notes: CA, ME, NJ, OH, and WA have included new construction as covered tasks.
Does OQ actually reduce incidents?
Asked directly whether two decades of Operator Qualification requirements have moved the needle, the panel was candid.
Alan Mayberry traced OQ's origins to an over-pressure incident and noted real gaps remain—OQ still doesn't cover construction, and carries an exception for emergency response. Kevin Speicher observed that training quality dipped in some corners early on (schools teaching to the test) but has steadily improved, with many contractor programs now rivaling operator programs. Jeff Wiese offered the sharpest framing: OQ was never meant to be about passing a test—it's about quality and genuine competence, the kind that catches problems before they become incidents.
Steve Allen pointed to where this is headed next: using AI and better data (drawing on RP 1186's emerging KPIs) to actually measure program effectiveness instead of assuming it.
Damage prevention and leak detection: two areas to watch
In the speed round, two items stood out:
A damage prevention professional certification program is currently in development through Utility Safety Partners, with Steve Allen and Jeff Wiese both serving on the advisory council. The upcoming PHMSA public meeting on advanced leak detection (tied to Section 722) will likely continue focusing on prioritizing large leaks and performance-based outcomes over specific technologies, per Alan Mayberry and Jeff Wiese.
Steve Allen's closing note on damage prevention: be intentional, be data-driven, communicate constantly, and lean on the Common Ground Alliance's Damage Prevention Institute rather than reinventing the wheel.
Speed Round Highlights
To close, each panelist fielded a rapid-fire question from host James Cross:
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Making OQ your own (Kevin Speicher): the program should reflect your actual system and operational realities—your tasks, your training, your evaluations. If it's your program, you shouldn't need permission to adapt it.
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How safe is safe? (Alan Mayberry): there's no fixed acceptable-risk threshold in the code—operators weigh multiple factors, from internal risk models to state commission requirements, in a landscape with little public tolerance for pipeline incidents.
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Where SMS falls short (Jeff Wiese): stakeholder engagement remains a major growth area—true engagement means listening, not just informing—along with weak continuous improvement cycles.
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Reducing excavation damage (Steve Allen): be intentional, be data-driven, communicate constantly, and use the Common Ground Alliance's Damage Prevention Institute.
What's next
EWN will continue answering unaddressed questions directly and keep the conversation going through LinkedIn and future events. The next Compliance Leadership Forum is expected in Q4.
James wrapped up the session: "Glad we were able to get into some of the hard-hitting questions—looking forward to answering more in the future."