The Standards Development Process - 3 Part Digital Feature
— October 29, 2024.
Originally published on WorldOil.com - Part 1 - Part 2 - Part 3.
This year marks the 100-year anniversary of API publishing its first standard. Since its founding more than a century ago, the American Petroleum Institute (API) has led standards development activities to advance safety and environmental performance, publishing more than 800 standards. These standards have become the foundation of both operational excellence and regulatory compliance, shaping the way that industry professionals work and innovate worldwide.
Standards development follows a structured and systematic process, ensuring the highest quality and likelihood of implementation by industry and regulators worldwide. World Oil (WO) recently spoke with Paula Watkins (PW), API Senior Director of Standards Development, to gain insights into the intricacies of the standards development process, the role of international collaborations, and the challenges along the way.
Her answers comprise a three-part series that will detail the initiation process for a new standard (part 1), the drafting and consensus building process (part 2) and the approval, publication and maintenance of a standard (part 3).
The following has been edited for clarity and space.
WO: How does API identify the need for a new standard?
PW: We rely on member companies, regulatory bodies, and other interested parties to identify where there might be gaps or a need for new standards. This can result from emerging technologies, regulatory changes, or industry advancements. For instance, we’re seeing areas for standards development related to technologies for hydrogen and carbon capture and storage, and we work proactively with the regulatory community and our members to identify gaps in our existing standards that require new ones, or where existing standards may need to be expanded to cover equipment and materials for example, for hydrogen service.
WO: What steps are taken once a potential need for a standard is identified?
PW: Proposals for a new standard are formally initiated by filling out the Standards Resource and Resource Request Form (Standards Resource and Resource Request Form, SR3) requiring key details, including the scope of the proposed standard, who would need it and why, the resources required to develop it, and the proposed timeline for document development. The proposals go to our Standards Policy Governance Groups, which focus on specific segments, like upstream, midstream and downstream. These groups review, discuss and potentially approve the proposals.
If the proposal is approved, API seeks out volunteers for the new standard’s development. It’s important that we have a balanced committee comprised of different interests with different perspectives, so we’ll try to include industry volunteers (which includes operators, manufacturers, service suppliers etc.), regulatory representatives, and other stakeholders such as academia and NGOs. Sometimes, we post on social media that we’re looking for volunteers. And sometimes, we’ll email regulatory agencies or industry companies seeking their participation.
WO: Describe the hierarchical structure for developing a new standard.
PW: There can be multiple layers of committees and groups. At the highest level are standards policy committees, which oversee the standards program management in a particular subject area. For instance, we have a Committee on Standardization of Oilfield Equipment & Materials in the upstream space, the Committee on Pipeline Standards in the midstream space, the Committee on Refinery Equipment in the downstream space, and many others.
Beneath these policy committees can be subcommittees, which drill down to focus on even more specific groups of standards within each segment. Further down, there are work groups and task groups, which handle the detailed work of developing the standards. These groups address ongoing aspects of standard development, from drafting of new documents to maintenance of existing standards, including continuous improvements or updates. Task groups may be temporary, created to tackle specific projects such as new issues or emerging technologies that require a dedicated focus for a limited period until the task is completed.
Each standards committee or group is led by a chair and vice chair, who help spearhead the development activities. Usually, the person who submits the SR3 form volunteers for one of these leadership positions, but the actual roles are formally decided through a vote or agreement among the group members.
The work or task group chairs may report to a subcommittee, which reports to a standards committee. We have over 10,000 volunteers participating in various committees and groups.
WO: What are the preliminary steps taken before the actual drafting of a new standard?
PW: Once we’ve identified volunteers, we’ll form work groups, whose members will start framing an outline of the new standard. Identifying this framework is important before we do anything else, so that the group knows what areas will be covered by the standard and where to focus their attention. Next, the group might conduct research, gather necessary information or consult with subject matter experts. Sometimes there are gaps in supporting studies or data, so API will address those by undertaking the necessary research, using specialist laboratories or other facilities. This preparation phase is important to make sure the group has all the necessary information and a clear focus before drafting begins.
WO: How does API handle transparency and due process during the standards development process?
PW: We’re committed to transparency and due process, it’s how we maintain our credibility and accreditation as an ANSI-accredited (American National Standards Institute) standards development organization. We have established procedures for the development process, make available draft standards on our website for public review and comment (allowing any interested party to submit comments), and allow for procedural appeals. These can be initiated by any directly and materially interested party who believes they are or will be adversely affected by a standards action.
WO: Why is ANSI accreditation important, and what role does it play?
PW: ANSI is the official national standards body for the United States, and their accreditation is critically important for API to maintain its credibility as a voluntary consensus standards development organization. It verifies that we meet its high standards of openness, transparency, balance and due process. ANSI audits API every five years to make sure that we implement and abide by our procedures for standards development.
In addition to working with ANSI, API collaborates with many other standards developing organizations to foster joint standards development, reduce duplication, pool resources, and guide global alignment, including (partial list):
ASME (American Society of Mechanical Engineers): API and ASME jointly develop standards related to mechanical engineering in the oil and natural gas industry, integrating mechanical engineering aspects with industry-specific requirements. EI (Energy Institute): based in the UK, EI and API jointly develop petroleum measurement standards resulting in the largest suite of standards on this subject promoting global consistency from all users of petroleum products.
WO: What challenges do you face in the standards development process, and how does API overcome them?
PW: A major challenge is the time commitment it places on our volunteers to do any one of the dozens of tasks to see a proposal through development to publication. Also, it’s so important that all voices are heard as we develop standards. That’s why we look for diverse representation on our committees, and building consensus can take time. But the onus is on API to recruit people who have different perspectives, and who each bring something different to the table.
Part 2. In the next installment, World Oil will delve into the drafting process, exploring how API navigates the complexities of transforming a proposal into a comprehensive standard ready for industry adoption.
This is the second in a three-part series exploring the American Petroleum Institute’s (API's) standards development process.
World Oil (WO) recently spoke with Paula Watkins (PW), API Senior Director of Standards Development, to gain insights into the intricacies of that process, the role of collaboration, and the challenges along the way.
Setting the standard for standards-setting. API is accredited by ANSI (American National Standards Institute), the organization that administers and coordinates the U.S. voluntary standards and conformity assessment system, verifying that API meets its requirements for transparency, balance, consensus, and due process. ANSI audits API every five years, ensuring that our standards development process adheres to these principles.
In the first part of our series, Paula explained the foundational steps that API undertakes to initiate the creation of a standard. She detailed how the need for a new standard is identified, and the review and approval process that unfolds before moving forward on development. The preliminary steps lay the groundwork for the rigorous and collaborative drafting process that follows.
Building on the foundation laid in Part 1, this article explores the complexity of the drafting and consensus-building phase. Below, Paula explains the steps involved in drafting, gaining consensus from diverse stakeholders, and the balloting and public review process that ensures the standard is fit for purpose and has the broadest applicability possible. This helps to transform an approved proposal into a comprehensive standard ready for implementation by industry and other stakeholders.
The following has been edited for clarity and space.
THE DRAFTING PROCESS (PRE-BALLOTING)
WO: What are the initial steps involved in drafting a new standard?
PW: The drafting phase begins with establishing or reactivating a committee of volunteer subject matter experts. This committee is responsible for outlining the standard’s structure, identifying key sections, and drafting the initial text. This process involves intense collaboration and negotiation among members to ensure all important aspects are addressed. Identifying a comprehensive outline is very important—this helps guide the group as it informs them how to buildout the standard’s content.
WO: How does API ensure a balanced representation of interests during the drafting process?
PW: We strive to achieve a balanced representation of interests by including industry (operators, equipment manufacturers, service suppliers etc.), regulatory agency representatives, and other stakeholders such as academia and NGOs. This diverse representation helps ensure that multiple perspectives are considered, promoting a more robust (and subsequently adoptable) standard. Achieving this balance is crucial for building consensus and ensuring all voices are heard.
WO: How long does it take to draft a new standard?
PW: Several factors impact the time it takes to develop a standard, including its complexity, the availability of volunteers, and the potential need for research to support the contents. Some standards can be drafted relatively quickly—in less than a year, for instance—while others may take a couple of years to complete (the longest time was 15 years) due to the need for extensive content development, collaboration and review. On average, drafting a new standard has taken 2.5-3 years. Standards addressing emerging technologies or significant industry changes may require even more time and research.
WO: What resources are utilized during the drafting phase?
PW: The drafting committee may reference existing associated standards, established industry practices, and input from subject matter experts. Additionally, they may refer to technical papers and studies to ensure the standard is comprehensive and evidence based. In some cases, API will hire a contractor to develop a first draft to kick-start the process, with other subject matter experts weighing in to ensure the resulting document meets the needs of the different stakeholders.
CONSENSUS BODY REVIEW
WO: What role does the consensus body play in the standards development process?
PW: The consensus body consists of voting members who represent different stakeholder categories, such as: industry in the form of operators, equipment manufacturers, and service suppliers; government (which may include federal, state, local, or tribal representatives); consultants, labor, and academia etc. Their role is to review the draft standard, provide feedback, and vote on its approval. This process ensures that the standard has broad support and meets the needs of various stakeholder interests.
WO: How is the public review process conducted?
PW: We make all draft API standards available for public review and comment [https://ballots-prod.api.org/home/OpenBallots]. This transparency allows any interested party to submit comments, ensuring a wide range of inputs. Both the Consensus Body and public review period typically lasts six weeks. This process is crucial for maintaining openness and allowing diverse viewpoints to be expressed. This public review ensures the opportunity for review by a wide audience and allows for comprehensive feedback, a rigorous process that helps produce the most robust final document.
THE BALLOTING PROCESS
WO: What is the significance of non-voting comments during the balloting process?
PW: All comments submitted on a ballot draft, whether from a voting or non-voting member, must be considered and an attempt made at resolution. Non-voting comments provide additional feedback and are considered just the same as those from a voting member, often leading to further changes to the draft. They are part of a process that strives to consider broad perspectives, even if they do not directly affect the standard’s voting outcome. However, all commenters have to be advised of how their comments were addressed, and reasons given if they were not accepted.
WO: How are comments resolved during the balloting process?
PW: Comments are reviewed by the drafting committee, who then prepare responses. If necessary, the draft is revised to address the accepted comments, and the updated version is reviewed again by the consensus body.
WO: How does API handle updated drafts and substantive changes?
PW: If substantive changes are made to the draft standard based on feedback received during the ballot, the revised draft undergoes another round of review by the consensus body. What’s a substantive change? It’s a change that directly and materially affects the use of the standard, according to the API Procedures for Standards Development. For instance, changes that affect the standard’s requirements or the addition of mandatory conformance with referenced standards would be considered substantive. When such changes are made, the revised draft must undergo another round of review by the consensus body with another opportunity to vote on the changes. Furthermore, any unresolved negatives must also be reviewed by the consensus body to ensure that all issues have been fully evaluated. This process continues until consensus is reached. The goal is to address all significant concerns and achieve general agreement among stakeholders. It’s important to note that unanimity is not always possible, and not everyone might get their first choice of a solution. However, our goal is to work towards a consensus, where everyone has the opportunity for input, and the result has as broad an acceptance as possible with the different stakeholder interests.
Part 3. In the final part of this series, we will explore the final steps of the standards development process, including the approval, publication and maintenance of a standard.
This is the final article in our three-part series exploring the American Petroleum Institute’s (API's) standards development process. World Oil (WO) recently spoke with Paula Watkins (PW), Senior Director of Standards Development at API, to gain insights into the intricacies of that process, the role of collaboration and the challenges along the way.
Part 1 covered the preliminary steps for project approval and committee formation. Part 2 focused on the drafting and consensus-building phase. In this final article, we turn our attention to the final stages of this process: the approval, publication and ongoing maintenance of a standard.
REACHING CONSENSUS
WO: What is required for a standard to achieve consensus?
PW: First, consensus is not the same as unanimity. However, consensus does require that the standard receives broad support from all stakeholder categories. These include operator-users of oil and natural companies, equipment and material manufacturers, service suppliers, with those that form the general interest category (e.g. consultants, government agencies, academia, and nongovernmental organizations).
For a ballot to be successful, at least a majority of the voters must return their ballots. Of those, at least two-thirds must vote to approve the standard. This requirement ensures that the standard reflects a balanced view and has gained substantial agreement among the voting members.
WO: How does API handle negative votes and comments?
PW:s When a negative vote is cast, the voter must provide a reason. The committee carefully reviews all negative votes and comments and works to resolve them. Sometimes, this involves revising the draft or explaining why a comment can’t be accommodated. The goal is to address all significant concerns while still moving forward with a standard that represents a broad consensus. Sometimes several rounds of balloting and review are required to achieve consensus.
FINAL REVIEW AND EDITING
WO:What happens during the final review and editing phase?
PW: Once a consensus is achieved by the consensus body (voting group), the draft standard undergoes legal and editorial review. The draft is edited for clarity and formatted so that it conforms to API’s Style Guide: there are some fundamental parameters that are used to ensure conformity of style for all API standards. Any queries that the editor might have are referred back to the standards committee for resolution to ensure no inadvertent technical changes are made to the document.
PUBLICATION
WO: What is the process for publishing a new standard?
PW: After the standard’s legal review and editorial work are completed, API publishes it and makes it publicly available through its webstore [https://www.apiwebstore.org/] and authorized global distributors. The publication process may also include communication efforts, such as publication announcements and press releases, which notify relevant stakeholders. API may also publicize the standard’s publication through various communication and marketing channels, such as LinkedIn and trade press articles, and may also provide more information in podcasts and webinars.
IMPLEMENTATION
WO: How does API support the implementation of new standards?
PW: Once a standard is published, it is reviewed at a minimum every five years by the responsible standards committee. If the committee determines that no updates are required, the standard is balloted for reaffirmation. If reaffirmed, that date is added to the cover of the standard. However, periodic updates may be needed for the standard – note that API Spec 5L is on its 46th edition!
WO: How are existing standards revised?
PW: Limited substantive changes can be made by issuing an addendum to the standard. These supplements have to be balloted and approved by the relevant standards committee.
When a revision of the entire document is necessary, it follows a process similar to how a new standard is developed. That begins with identifying the need for a revision in a project proposal, followed by drafting, review and balloting. API solicits input from the industry and other stakeholders to ensure that the updated standard continues to serve its intended purpose effectively and meets the needs of the different interests.
Updates to API’s standards can be made through these different mechanisms, ensuring that the standards constantly evolve to meet the needs of the different standards users.
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