Chipping Away At Cross-Border Differences with Dr. Nicki Robertson

0:00 Rhett On this episode of Pipeline Things, we bring on a special guest to talk about the differences and similarities between U.S. and Canadian regulatory. There are no fights, no blood is drawn, but it is a great Mulligan episode with our guest, Nicki Robinson. We think you'll enjoy it. Thanks for joining us. 0:30 Rhett All right, welcome to this edition of Pipeline Things. I'm your host, Rhett Dotson, my co -host, Christopher De Leon, as we continue in this arc. I am excited for a lot of reasons on today's episode, Chris, but before we get started, I need to know how you feel about a certain rule in disc golf, right? Okay, so On the first hole, are you allowed a mulligan or not? And what are your thoughts, right? Because in some people, look, I won't say on our team, think that if you don't use the mulligan. So for our audience, it's not familiar, right, with golf terms, right? If you get up to a hole and you shoot a bad shot, it's that you get a free redo and it doesn't count as a stroke. 01:10 Chris Everybody laughs at you still, but you get to try again. Rhett Oh, yeah, open field, open season for mockery, right? But There's this belief that since it's the first hole for some reason, if you get up and throw your disc the wrong way, you just get a free redo. And then some people are like, hey, look, if I don't use it on the first hole, I can use it like on hole six. Some people just think that every drive on every hole is a free mulligan. So, Chris, what are your thoughts on the mulligan? 1:30 Chris I think it depends on how you're feeling and how competitive you are. I think we kind of have a vibe where it's like first hole you get a mulligan but it's use it or lose it like if we're pretty close down the stretch or we're at the turn of hole nine and I want to redo it's like no that's I agree no that's but the first hole it's kind you're kind of stiff you're in Houston's you're likely in traffic your hands have been at 10 and two so first holes mulligan after that 2:03 Rhett Do you get to choose which disc or do you have to take the second one if you do them no you can choose your disc so you can throw two oh yeah and you can choose which one Chris Yeah okay I think that's fair that's cool. Let's be real because you want competition too you know what I mean like you didn't just want to I mean well it's fun to destroy them through the 18 whole course or nine if you're doing a short but 2:22 Rhett Did you ever really fall apart on the first hole I mean you can get off it's not like college football you can lose a hole and come back and make the next 10 work. 2:30 Chris I don't know, but I mean, because if you hit it right, it kind of sets the tone. You're kind of excited. You feel like you're on. Whereas if you like shank the second one too, you're kind of like, oh, boy. Rhett Oh, God. Shank the second one. So yeah, you know, audience, for those who you are wondering, like, let's be real clear. Chris and I, people ask us, we shoot the podcast one and done. Like, we get in here. We do it live, baby. We do it live and you take what you get, except for this episode. Yeah. So this episode is 100% a mulligan. And I think, but you know what? The first disc we threw might have been a foul, but I'm pretty sure that the second disc is going to be a home run. 3:08 Chris I don't know. I would say this is very much like doing it live, but there are no edits. Like we're doing this. It's coming out. Like, we don't know if we should let the person review it. We should just drop it. Rhett 100% dude. Shoot and let's go. So that's it. So to our audience, our guest today is our partner in Canada, Miss Nicki Robertson. I'm going to bring her on. And in full disclosure, this is the second take on this episode because the first take, Nicki was too nervous. We didn't get real Nicki. So we were like, dude, we got to do a mulligan. And on take two, we got to see real Nicki. So I'd like, Nicki, welcome to the show. Will you introduce... Welcome back. Will the real Nicki Robertson please stand up? 3:55 Nicki Thanks for having me back. And letting me do a retake. To remind you its actually Dr.Robinson. You know, it's in a miss, but I worked real hard for that degree. Miss is nice,but doctor works too, you know? Anyways, I just joking. It was a great experiencein grad school. 4:11 Rhett You know, Nicki, I got to be honest, I thought whenever you did that whole bust, which is really good. I thought you were going to apologize right after. Like, no, I'm sorry. I'm just kidding. But you didn't. So it's good. We're making progress here on the apology spectrum. Nicki We're making progress on my cultural problems. Chris I also feel like this episode, you're getting a whole lot more of like the partnership vibe here, right? Like, you're much more comfortable in your seat. You know, you're willing to check somebody or two. So I feel like this was better timing anyways. Rhett So there we go. So Dr.Robertson. Will you please introduce yourself. 5:00 Nicki Oh my I was just joking. Dr.Robinson is my grandpa not me. Hey everybody. Thanks for having me. So my name's Nicki. I live in Calgary, Alberta, and Canada. That's not the 51st state, but you know, your neighbors and friends up north. Yeah, I joined D2 back in June, partnered up to open the Canadian office and I've been having a blast. Before that, I was at a couple different operators for a baker's dozen's worth of years. And before that, I did my doctorate at the University of Alberta. 5:33 Rhett And before that, you were in the States for school, right? Nicki I was, yeah. So when you're talking about golf, I went on a golf scholarship down to Minnesota. So sometimes you hear the little down at the bubbler. Rhett So it's to all our clients out there. We are accepting challenges now in a golf scramble format, which will basically be Chris and I hitting clubs like like Chris No no no more like caddying for her. Rhett yes Chris and i catting for her Chris I'll be the club caddy since I don't know if you know golf clubs do you know golf okay then I'll be ball caddy 6:00 Rhett oh you mean I would tell oh I just pull all them out and tell you to pick which one you want Chris I'll be I'll be club caddy he'll be ball caddy he'll be ball caddy he'll carry the sand around too 6:10 Nicki You know you guys have uh really helped support set up the canadian operations up here. You've been more than just a caddy, but coach and everything and definitely appreciate it. 6:20 Rhett So I'm going to set the tone for this episode for our audience. So the reason we brought, and you might wonder why we bring Nicki on, it's because we're going to talk today about the differences between U .S. and Canadian regulatory environments. And we think that no person perhaps has, you know, maybe more to say on that subject and is a better guest than Nicki. So, Nicki, I want to just give you a little bit of background on why this topic, for me, I'm looking forward to it. For our audience that are listeners, you know if you listen to the first Failure File series that we did. It had a marked impact on me. And because I think for most of my career, I was always under this, hey, you know, performance -based regulation is good. It's what we should move to. But I felt as I was going through the first Failure File series, I had this real internal struggle of being like, oh, I see why we have prescriptive regulations now. I see why we have prescriptive regulations now. And by the end of that series, I really felt like I think I'm on the prescriptive regulation bandwagon. And that my reasons are that I'm sorry, but I feel like if history teaches us anything, it's that we often don't do what we should do sometimes. And so enter prescriptive regulations to just require it carte blanche, right? Which is more expensive, but then ensures a minimum level of safety. Going a little bit further than that, even Andy Drake's episode, he gave the reasons why they did it. And it's because, you know, he said, look, you know, the U.S. regulatory environment is completely different than, for instance, in the Canadians. And we're going to talk a little about that. But Nicki, specifically, what have your experiences been? So help the audience understand a little bit why. What's your background in dealing with U.S. and Canadian regulators? Have you had to deal with both? 8:13 Nicki Yeah. So I've dealt with both the CER, that's the Canadian Energy Regulator, as well as PHMSA. I've also dealt with the BCER, that's a provincial regulatory body out in British Columbia, as well as the Alberta, the Ministry of Regulatory, which Ministry of Environment and Regulation in Saskatchewan. And then yeah, a few state regulators as well through my time at my various operators. It's interesting, though, my experience in the U.S., up until working with the two of y'all, is been from a Canadian perspective trying to learn the American system and fitting into that, making our programs work for that, versus now the last couple of months I've had the opportunity to get to see the American clients from a different perspective. and it's been quite eye -opening to be able to work on the cross-border. 9:17 Rhett So talk to me a little bit about that because, again, my perception in the time that I was working as a consultant has always been that the Canadian approaches. And I don't like the term, but I'm going to use it better, right? That's how I think it's presumpt. It is, right? But I think people feel performance better than prescriptive. Performance greater than prescriptive. And I'm curious is what your perception is... 9:44 Chris Some would interpret that as just flexibility. Maybe not better. Rhett Fair. You improve my words, fix my words, change my words. My question is having worked on both, how would you characterize them? 9:58 Nicki It's pros and cons, I think, from an outsider looking in. I definitely enjoy working more in the Canadian regulatory framework because you can, as Chris mentioned, the word flexibility, be able to actually use science and math to make the best risk-based decisions and spend your dollars the most wisely versus the checkbook exercises that it comes across as when going through an audit. But I think it's just the different ways that they're put forward. Yeah, I could go into a whole bunch of tangents. 10:37 Rhett No, so when you say science and math, like let's be real, like give me an example. Maybe Dents is a good place or unless you think there'd be a better threat, right? So like in the US side, you're saying that, for instance, Dents are above a certain depth for a long time you had to dig it 10:50 Nicki Yeah um it's a if this then this then do this right yeah kind of Rhett that's the U.S side if then do this then this yes Nicki versus almost every clause in CSA uh has a way to say or engineering assessment and or engineering assessment and so there's always a way that you can use you know the code sets a minimum of things to think about but there's always an out or an EA and that's really fun as a pipeline integrity engineer because you get to always be learning and involving new techniques new methods and trying to push the limit to what makes sense to spend our money on it and what what doesn't make sense Chris so I'll ask maybe this question tie it to to Rhett's comment right so Rhett brought up the episode where we talked to Andy Drake and the idea there was you know in the US Phimson needed somewhere to start from a pipeline safety perspective we started with HCAs and then the ideas was to grow through all different classifications of pipe. And the prescriptive component of it established a floor of safety, like a minimum requirement, and so in the US it was clear they thought that was the need to be more directive about how to start this journey of pipeline safety through pipeline integrity. That seems cultural to me. What do you think, your personal perspective, why is it that you think that the Canadians don't maybe need as strong directive towards the minimum standard of safety to where you have to prescribe exactly how you should respond to things and that you guys are given the flexibility of an EA? 12:30 Nicki Yeah, so I think it comes, I think there's two things there. So I'm going to say one, and then I'm going to go two. So one thing to that it's cultural, I think, about the way the evolution of the oil and gas pipeline system is here, both generationally and how our regulations come about. Because up until quite recently, it was all the baby boomers that were running all these companies and they were really a part of like the forefront of the explosion of the oil and gas industry 13:03 Chris what explosion which one in particular belling like something like bellingham or something else Nicki I just mean like the industry taking off right a lot of growth um yes bellingham also is where integrity got it started and instead of waiting for an incident to happen north of the border okay it was a lesson right away, let's go. And I think because the industry was very heavily led by engineers, it was, and our approach culturally to engineering is self -governing, that we kind of went down a different path. And speaking to kind of that engineering kind of type path, it was just kind of wrapped up some Canadian standards and association meetings this week and it's just amazing to see all the volunteers that come together to write the code and so as my um may rest of peace my father always said the code is written in blood right and it's engineers coming back putting in those lessons learn and our frequency of of getting those lessons learned in are every four years. And they're written by engineers, for engineers, versus my perspective is that, you know, your CFR regulations are written by government, enforced by government, right? And so it's a bit of, it's a bit of a different take. 14:31 Rhett Wait, wait, can you say that again? Did you say written by engineers and enforced by engineers? Written written for engineers, written for engineers. By engineers. 14:38 Nicki By committee, right? Everybody sits in a room and they'll argue about the smallest little word for an hour and a half because of how it could be interpreted and the commentary that goes behind it. I mean, it's awesome. I love it. 14:50 Rhett It was interesting. You said that and you said written by government for government. I don't actually know that I disagree with that. But it just really made me think. I thought it was a fairly profound slash provocative statement. How often in y'all's interpretation are operators involving attorneys? And I want you know why I ask, because I don't know if she knows, right? But a lot of times in the U.S., when a decision about a regulatory thing comes up, attorneys get involved. Regulatory attorneys get involved. I didn't say regulatory engineers. They're also involved. But regulatory attorneys in the interpretation for legal reasons. And that made me wonder, do you all have similar things on the Canadian side? 15:35 Chris And so much that just to give you feedback, like we have a whole culture around it, what I coin Rhett’s terminology of interpretation mechanics, right? Everything from the code to now FAQs where FAQs weren't law, now they are law. And then the punitive measures that are taken because of interpretations. And so it's become quite a deal. So you're commenting around, you know, the political component to our regulatory environment and how we implement integrity management, they are married, right? 16:08 Nicki Very much so in the U.S. And I would say they're much more separated up north. I mean, there are regulatory lawyers up here as well. I would say they get more involved in the environment side of when things go bad. Sometimes it comes in more with like development type things, but when it comes to failure and technical reasons, that is typically always left to the engineers. And then, you know, to different regulatory frameworks to do the investigation, but they try to keep it fairly technical. It's not, I mean, companies still sue each other, but it's not regulatory. 16:45 Chris Yeah. I think something that would help maybe frame the conversation also for our American listeners is, how does the pipeline industry regulation come about, right? So is that driven by on the Canadian? Yeah, because and I won't say names too many, right? But there's several regulatory bodies. Like, for example, in the U.S., we have, you know, the state requirements that are as a minimum, the federal requirements. And then depending on your jurisdiction, one of them reigns over the other. And they're responsible for doing the inspections. I don't want to get to maybe that depth, but just maybe a little bit higher and say, How are the regulations established in Canada? And what are the biggest components or the biggest gears in that machine? 17:37 Nicki Yeah. I would say it's simpler north of the border than it is south of the border. But that's my bias, right? And that's if you have an interprovincial line or you guys would say interstate line that is regulated by the Canadian energy regulator. If we cross from a province into the U.S. of A, that is also the federal regulator, the CER. But if your asset is contained within a province, it is 100% the provincial regulators jurisdiction. And so, but in all of our regulations, though, It should, depending on how the company has licensed it, it should be AER, if it was no bird of, say, and B .E. 18:30 Rhett Just want to make sure I understood that. I'm on board. Chris So now, how do those regs come to be? So you said, for example, earlier you said CSA and engineers come together every four years, for engineers by engineers. 18:40 Nicki Oh, my gosh. They're working like right now. This is a plug for CSA, public review, everybody. January, it's coming out for public review for feedback. And any new changes that are going to go into it, that's 2031. Chris So CSA governs interpipelines or intra pipelines? Nicki CSA is the Canadian Standards Association, which is incorporated by reference on our federal onshore pipeline regulations as well as each provincial regulatory body has incorporated CSA by reference the most current edition for most of them that could be wrong and then they have some additional requirements that are specific to their province so at its most part they're very similar 19:25 Chris So in the bones of it engineers get together every four years roughly an issue in issue standards a year yeah but I'm saying every four years, you'll get a new version of it. Yep. And it's common practice for the regulators to incorporate that most recent version. 19:43 Nicki At the time it is released, there is no waiting period. We drop it and then you have six months to implement it. Rhett Yeah, I've got to be honest. That is kind of cool and I'd say a bit impressive because, you know, that's one of the challenges. Like when we talk to Jerry, Jerry said standards should drive regulation. But I think unfortunately the United States, again, because of the prescriptive nature, regulations often happen apart from standards. I want to go back a couple of questions that you raised. I was just writing questions, Nicki, when you were talking. You mentioned that, you know, during your recent time with us, it's been eye -opening for you to see some things on the U.S. operator's side. What do you mean by that, right? Keep their names out of it. We want to get in trouble. Keep their names out of it. Don't talk about people specifically. 20:23 Nicki Well, before as an operator at, let's say, a client, yeah, for that, you know, get your abstracts in, we maybe wouldn't have had as open of conversation discourse because someone may overhear something and fear of action from a regulatory body off of being super transparent and sharing, sharing true struggles versus the Canadian operators typically are a little bit more blunt. I don't know, maybe it's cultural. But it's also, I think there's less fear of getting penalized. And so, and I think it goes to that prescriptive versus performance-based component too, where we're all sharing lessons a little bit more openly to get to performance versus if you share lessons learned in the U.S. to get to performance and it doesn't check some whatever box or it could check an interpretation a different way, there's fear. So folks, I always took it that maybe folks were a little bit more guarded and now I kind of see like there's a very different approach between what they really think and what they say. It's very impressive. I don't have a political skill set. 21:44 Rhett Yeah, I think essentially what you're seeing is, or what you're describing to me is absolutely, like in a room or a conference, operators on the U .S. side will not speak up because they know there are regulators there and what you say can and will be held against you in the court of law, so to speak, right? And so a lot of times operators will things that are not outside of code or they're addressing problems, which they feel is the appropriate way to do it, but because of how it could be interpreted or could be understood or misinterpreted, I will say. They don't share it. Yeah, they don't share it. And they're reluctant. You're absolutely right. I mean, that perception of U .S. operators, I think, is accurate. Now, in intimate circles, they may open up, but those are pretty rare situations so hey um you have another question 22:31 Chris well yeah i want to get one more thing to kind of catch this whole vibe right so in the u .s you know audits are a big deal from a from a like a compliance perspective um and there's different ways that we won't get into on on the call about how those happen and the pros and cons of them and it's again in the simplest form talk to us about out the audits right So, you know, what would you feel, what are some of the drivers, I guess? And often how would you describe that relationship between an operator and a regulator in an audit setting? 23:07 Yeah, so that's that, I'm going to dodge your question like a politician that I said. Like a metallurgist? Oh, she's learning. Yeah, she's adept. It depends. You know, even on, even on the code committees, right? Yeah. Engineers for engineers, there's audit, there, There is different regulators, that's the word, that are sitting on those code discussions too. And so when they're openly talking about how we change code, they're also a part of it real time. So when it comes to audits, I think it depends on which regulatory body in Canada you're working with. But our provincial, In general, our provincial regulators are partners with us, with the engineers, for the most part. Like, we all want the exact same thing. The way that you typically get selected is they have quotas for randomly checking different assets within inside different people's portfolio. And if you're a good performer, you stay the minimum. And if they start find stuff they your frequency will increase or if you have an event then you're definitely like if you have an event you're getting you're getting restrictions put and sanctions put on you and it's like it's a it's a daily if not weekly conversation to to get those lifted so Chris 24:27 Do you guys have a big reporting process where operators are reporting specific information to to a regulatory body which may or may not be influencing the regulator's actions 24:35 Nicki Yeah um the federally there's the information exchange that happens annually where they get a set of information it's the standard set of information year over year and that's just to track company profiles and also performance um and then we have a a big sit down and you go through it with them page by page, question by question. Sometimes it can take a week. Sometimes it can take a couple Weeks. And then on the provincial side, there's different recording thresholds depending on province by age too. So if you have an aged asset, they're more interested than if you were built a newer asset for reporting requirements on integrity management programs and then obviously if you have an event there's a similar to PHMSA there's a reporting mechanism so they can track 25:33 Rhett Well hey I'll tell you what so the mulligan's going much better we're taking throw number two for sure Chris I feel like we're on the fourth basket already at least on a nine hole short course we're at least halfway through now 25:47 Rhett When we come back I want to talk to you a little bit more about, about these EAs and quality. You've got some questions I want to ask you. Audience, hang on. We'll be right back with our guest, Dr. Robertson, when we return. 26:03 Rhett All right, audience, welcome back as we continue our conversation with the expert ball golfer, Dr. Nicki Robertson, and talking about our conversation, you told you, I was going to go with it multiple times. It should not surprise ball golfer too I keep ball golfer yes she is um what's the best round you ever shot Nicki 26:20 Nicki Uh I shot 35 on the back nine for my junior club championships when I was 17 that was the best nine holes in my life i was uh three 400 and I won it with a 70 78 it's a junior junior in college uh 17 17 so it's the championship yeah i was in high school cool cool uh 26:50 Rhett If you went out and played now how what would you play Nicki not good yeah i played twice a year in scrambles in industry events up here I love it um 27:01 Rhett What part of your game suffers the most is it the is it the short game is it the putting or is it just driving Nicki I've always been bad at putting. I used to have average of like 40 putts around. People are like, what is wrong with you? 27:11 Rhett Is it because you overthink it? Nicki 100%. Just like the reason why I needed a mulligan on this podcast. So, all right. My husband, so plug, my husband and I used to play pickleball in a league. And anybody knows pickleball. It's called dinking when you go back and forth across with essentially a volley like in tennis and um our team name was uh over dinking it so yeah it's a household problem yeah throwing shade now on them that's not nice of me 27:41 Rhett Um I didn't know we you uh in that throwing shade you assume that we thought he was the one over dinking and not necessarily you uh so Nicki It's the household the household problem um oh yeah Rhett Poor Emmett's getting drug into it now. Rhett Back to EA's. So, Nicki. E .A. Sports. Dude, that was, that was good. In that first half, you mentioned that y 'all are self -governing, self -regulating on the engineering side, right? And that's how you have so much confidence in the Process. My question was, when you're doing these EAs, how do you ensure that you get sound engineering right from from whoever's doing it right because in my mind I'm thinking if somebody wants to be because we've seen which less scrupulous we've seen this if somebody wants to be less scrupulous you know it's it's almost like look in the United States to get in a legal battle you can you can find an expert witness who has a PE license who will tell you whatever you want and I imagine if I wanted to do an EA north of the border, I could probably find an engineer who's willing to sell their stamp. And I don't mean sell it literally. I mean sell the answer figuratively and then put their stamp on it. So how do you, how do you protect against that? How do you, how do you ensure sound engineering? 29:03 Nicki Well, I think how we have done it and how it is going now are two different things. I think there's a bit of an erosion on it. But I would say how we've traditionally done it and how when it works. You have a process through your body that governs the engineering practice. Those are all volunteers as well as paid people who support the management of the engineering practice in each province. 29:33 Rhett And then from that - So is this like a APEGA? Help me understand is you speak about things like APEGA okay gotcha Nicki APEGA a pegs etc bc engineers um and so those folks oversee and so if you see an infringement by an engineer you are to self -report and then that goes to a body of folks who review all the information and then apply penalties. And the penalties can be anywhere from thousands of dollars to you lose your license. 30:10 Rhett Does that happen a lot? Do you get a lot of self -reports? I. E. Snitches? Nicki They're not snitches. I actually think that that is the reason why I think that it's not working out as much anymore is Because culturally, it seems snitching when really it is holding others accountable so that you don't need to have a regulatory body. 30:33 Chris So is it common for one engineer to snitch on another? So by self -reporting, you mean from the same body? Or do you mean self -reporting as like the person says, I made a mistake and I need to let everybody know I made a mistake because I'm a good person? 30:46 Nicki No, no, no. It's a new snitching. It's It's not snitching. It's reporting. It's upholding the engineering standards. Chris I love it. Hey, I'm with you. We haven't said anything different. Nicki That's one part. And then the other part is, you know, and we have it at D2 integrity. 31:02 Chris Have you ever snitched on somebody? Oh, I wish I could. So bad. There's a few. I was just curious what we got into here. Maybe that should have been. I haven't. For the record, I haven't, but I have talked to my own. Rhett She got real close. She wrote it up. She was about to hit send. She slept on it for 24 hours. Yeah, yeah. Nicki And then the other part of what I was saying is that at D2 Integrity the way we review reports. A writer, A reviewer and then approver. That's a similar process, but instead of it just being D2 Integrity’s process or good engineering practice process. It's a mandated process and we have different words for it. So you have the, I'm not going to mess this up, the authenticator. That's the person who is taking professional accountability for that work. And then you have the validator who ensures that the company's quality processes are being followed in order to release that work. And so anything in APEGA made this beautiful, like, infographic diagram. Anything that you take values, you apply math, and you make a decision off of is called an engineering work product. And so all of that work that's done by an engineer or a licensed professional or a professional technologist all needs to fall within side that scope. 32:30 Rhett You just use three different terms. Those don't all have to be licensed PNG people, those three people. Nicki Yeah, so APEGA does more than just engineering. They do engineering and geologists. And recently, the asset for Alberta Society of Engineering and Technologists also have joined in. And so there's different names based on different educational background and components and then also areas of expertise so you can become a licensee which is equivalent to a PNG in a space but not in all spaces and you so there's there's some nuances there 33:14 Chris Seems like it's engineers looking after engineers versus it being regulatory bodies which are a composite of every background and motivator governing engineers. That's the simple takeaway, as I understand it. 33:32 Nicki 100%. So I get really passionate about when you say snitches, because if you want the luxury of being self-regulating, and that means that you have that much trust from society that you're upholding things and so that's why um you know you talk about engineering i'm a third generation Canadian engineer so it it's like a family culture 33:54 Chris I can appreciate it the reason why I say it that way is one to just get a roll out of you but two it works because here's south of the northern border um you know there's this whole idea of um safety management systems is kind of like the evolution of integrity, right? So integrity is a component of a safety management system. And safety management systems rely a lot on self reporting, not snitching, right? Where I would say the distinction is self reporting is, I know I made a mistake. And so I will put this into the system so that others can learn from it. And so it's building that confidence in that being careful about punitive measures such that the individual who recognized it is the first person to speak up versus it being peer -based where if that person didn't self -report and someone else saw it, you might approach them and say, hey, we think you're just self -report because if you don't, I will. And so that was just a little bit of a facetious way to highlight the difference where not that one is better than another, just the path that we begin to see here in the U .S. is people really trying to push towards this this safety management system, right, where it's a little bit more about true self -reporting from each individual. 35:04 Nicki So from an integrity program perspective, we have that. We have voluntary self -disclosures. Rhett So going back, right, before Chris insulted you guys by calling you all stitches, right? We didn't say anything about stitches yet. Everybody knew that was going. Nicki, You kind of mentioned an erosion. I'm curious what you meant by that statement, right? Because that seems, look, I'll just be honest. It seems like that's a very... 35:35 Chris I used erosion because she said a APEGA then brought in a geologist, and so you like me. I love how she... You see how he did that? He's so clever. Erosion to yourself reporting. Does that mean all the geologists fell off? Is that what you mean? Nicki Now the geologists are great. No, but the erosion that I'm kind of referencing is that I think in this generation of AI and computer power and technology, I think the importance of engineering in Canadian culture may be seeing a bit of a decline. And I say in a sense that no longer are companies looking for long -range plans and long -range profitability, everything is so much more quarter, quarter, quarter, quarter, how are we going to do it quicker, faster for less? And so with that, I think, comes the, and you can see it from the composite of major mid –stream companies and the percentages of engineers that they have and leadership positions is dwindling, you know, year over year. And so that trickle -down effect of the importance of engineers making the right decisions for the right reasons with the right technical justification, you're starting to get a lot of financial push on it. 36:56 Rhett I mean, look, that's real easy. You want to get profitable. You just replace engineers with processes. I don't understand what's going to say. Chris Bingo, that is literally what I was going to say is it's here on the U .S. side, like, regulation has become such a fundamental part of pipeline integrity. People don't do math anymore, right? Yeah. It's even like my kids, like half of my, well, I guess. What do you mean math? Hey, hey, Google, that's what it is. Like, I'll put it like this. My oldest child has fully embraced technology. And refuses to do decimal math or fraction math because it's a process that she doesn't want to go through when all I need to do is know how to use technology. Whereas my seven-year-old is like, it is so cool to do long division. I want to do this, right? So I know which one is going to be an engineer and which one is not. And I feel like a lot of integrity is kind of going that way, right? Like I remember when I first started and Jerry was on there, right? It was kind of like, I got to do a lot of the math, right? I got to figure out like, okay, what is this metal loss feature? Why do I trust the ILI Data? I'm going to run the calculation in a spreadsheet. Then we figured out how to bring that in their GIS. And then I was like, well, I don't know if I trust it. So I'm going to do the math anyways. And you go down this whole path of I'm still an engineer. I need to do the math. And a lot of the times now when we talk, I mean, outside of D2 Integrity, it's a lot of just about process, right? Like, oh, well, we wrote up a spec and someone else did that. But they're the integrity engineer. And I'm like, well, if you're the integrity engineer and someone else did the math, how do you know the math was right? And so I think, I think you hit on something really important. I don't know if it's generational or maybe just a product of the levers around pipeline integrity, which maybe aren't letting engineers be engineers. And so I'm going to, I want to use this as a segway if you don't mind, because otherwise we'll go down that sidebar a long time. It makes me think about EA, right? So Rhett brought up the question of sound engineering. And you and I have had a whole lot of talks about EA, right? You're like, oh, we'll just do an EA. And I'm kind of like, oh, okay, like you use EA like a like a joker, right? Or like a get out of jail free. Like I can't. Exactly. And I'm like, where's the process behind this? Like, oh, just do an EA. And I'm like, what you said are going to do a EA on class? You're going to do an EA on dents. You're going to do an EA on a metal loss feature. I'm like, give us a vibe for those of us Americans that are used to processes and you have to have a written procedure for how you do a process. What is an EA and how do you use it? 39:13 Nicki So an engineering assessment is a debated term, but it is used in CSA. And what it really means is that you can limit the bounds of what an engineering assessment is. It means that you document all your data inputs, you figure out which methodology is fit to solve the problem that you're seeking to like what what what question are you trying to answer and then going through these methodologies work here's my criterion of what past looks like and then actually doing the math and the analysis and putting it together and saying did we meet our objective is it does it go through you know does it pass or does it not pass so for like a dent assessment for say there's a clause in It says susceptible to fatigue. Okay. Well, what does that mean? That's pretty broad. How do you know if it's susceptible to fatigue? Well, you've got to do an engineering assessment to know what's your cycle loading. 40:08 Chris So you did an EA and in an EA? Nicki Yeah, 100%. Chris That's not confusing. Nicki And so anytime, and it goes back to that, a peg of work product, right? You can, you can deem a lot of different work EA. And so I like personally and the Canadian Energy Pipeline Association, which ceases to exist, CEPA, came out with the different types of levels of a EA. And so level one is something that is routine, self -confine, feature -specific. And then level two would be something that is threat -specific or area -specific. And and level three being the whole pipeline, every threat under the sun. You don't get to put your blinders on and just do one subset of analysis. But you could have a debate between a whole bunch of us about what the heck an EA means because in some organizations, it means something much more specific than what on. 41:05 Chris Do regulatory bodies review and approve your EA process or just the results? 41:11 Nicki They review and approve neither. You as the operator have to review and approve it, right? Chris I was just checking the waters here, bro. 41:21 Rhett They self -regulate, bro, self -governance. 41:22 Nicki So, but you make a good point. So at every company, most operators have a, here's our engineering assessment process of how they go through the engineering and then they follow that. So then when they say, okay, what's your process for quality or sound engineering? Here's what it looks like. And a funny thing on that, I was in a CSA meeting, and competency got brought up. Well, they need to be competent in this. They need to be competent in that. And so that's a whole other rabbit hole that we'll have. 41:49 Chris Hey, as long as you have that little pinkie ring, you're competent, right? No, I thought it works. Rhett Let's bring that up. But I do like the ring. There's the ring. There's two of them. Look, that's a 31 -8 topic too, man. It's been a big deal. But we definitely don’t have enough time to get into that. I think it's actually a really good, really good to wrap it up, Nicki. And I want to say, um, we well done. Second throw was much better than the first. that was really good. Chris We finished the front nine. This is good. Um, absolutely. And, and to our audience, I don't think it's the last time you'll hear from Dr. Robertson on the show. Chris If y'all don't know, again, one of our big things on the podcast said, to bring cool people to the forefront. I'm going to be honest with you. We hired Nicki because I think she's awesome. So if you don't know Nicki, I know all of you people north of the board know Nicki, high energy, energy, brilliant, great personality. I know we feel super blessed to have her on the team. But for those of you that don't know, Nicki, you know, like my 12 -year -old would say on her, on her YouTube videos, you know, like and smash the subscribe button. Like find her up on LinkedIn, friend her, invite her up for coffee. Don't be shy. She's great. We think you'll love her. 42:51 Rhett For sure. And Nicki, thanks for joining us. Really appreciate you being here. To our audience, it's been great. We'll see you guys again in a couple of weeks, and thanks for joining us on the show. This episode was shot at the Workwell, produced by Sarah Etier It wasn't written by anyone. It was shot half Canadian, half US on the spot.