A review of dual assurance, data normalization and management of change, and improvement process

Dual Assurance

Here a leading indicator at a lower level is matched with a lagging indicator at a higher level. The goal is to predict where performance of a process is clearly and directly tied to performance at a higher-level objective.

Data Normalization

Normalization is necessary to compare data between various operators. For example, if the definition of a leak is different between operators, then it is not possible to compare their KPIs.

Management of Change (MOC)

Pipeline operators shall apply their formal MOC process as required in 49 CFR Part 195.446(f).

Improvement Process

Identifying issues for improvement and monitoring the improvement process for the identified issues is an important part of the LDP. KPIs that are specific to the improvement process should be tracked and reviewed for progress. Operators should develop a process to capture improvement suggestions.

Possible specific items for inclusion include:

  • Information provided in the overall LDP evaluation and covering leading and lagging indicators
  • Lessons learned from the review of three to five years of industry leaks or leak alarms (where these exist)
  • Issues encountered in the maintenance programs and analysis (i.e. worst actor/bad actor, updates to the FMEA)
  • Gaps identified by KPI evaluation, event analysis, Root Cause Analysis (RCA), where parts of the LDP failed
  • Performance monitoring results as recommended in the performance-related sections in the RP
  • Apparent trends that indicate issues with the pipeline operator’s leak detection capability or effectiveness
  • Results from examination of software upgrades
  • New detection techniques and evolution of the state-of-the-art that offer features that promise improvements to the LDP or do not have common points of failure with existing LDSs
  • Results of tests that indicate disconnect between expected and actual performance
  • Information on frequency of threshold adjustments
  • Information about new shipping routes or products
  • Assessment of where the strategy is not being fulfilled (gaps) (i.e. adding instrumentation in one part of the pipeline)
  • Facilities, instituting within whole pipeline system
  • Training concerns

Initiating and Monitoring the Improvement Process

During this initial process of planning, all of the suggestions, requirements, and new continual improvement targets should be reviewed.

Actions, for example, may be:

  • Defining and recommending a project to make the improvement
  • Performing maintenance to make the improvement
  • Making changes or adjustments to make the improvement
  • Other efforts such as evaluating, planning, etc., that lead to improvement

Timeframes should be determined and resources should be assigned to various types of projects:

  • For maintenance improvements, the activity should be performed with verification of the outcome. The MMS or CMMS may be used as appropriate to track the outcome of the maintenance activity.
  • For a change or adjustment improvement, the work should be fully documented.
  • For other types of improvement efforts, if the action is some evaluation, planning effort, and/or investigation, then the effort should be fully documented and any further steps defined and planned. Any of the improvement types may be coordinated with and use the pipeline operators MOC process as appropriate.

After reviewing the inputs and defining actions, a simple checklist may be used to review the LDP. The checklist may be a simple review of the LDP areas as forth mentioned in this RP, examples are as follows.

  • Were inputs included in the review?
  • Were KPIs and targets part of the review'?
  • Were continual improvement targets identified?
  • Were actions identified?
  • Were last year's actions completed?


  1. American Petroleum Association. (2014). Recommended Practice 1175, Pipeline Leak Detection Program Management (2st ed.). Washington, DC: Author.

A Look Inside API Recommended Practice 1175 Series

By: Atmos International
Date: 17 April 2019