Episode 2

July 09, 2025

00:42:39

Failure Files 2.0: Boeing

Failure Files 2.0: Boeing
Pipeline Things
Failure Files 2.0: Boeing

Jul 09 2025 | 00:42:39

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Show Notes

An Important Note: This episode was filmed before the June 12 plane crash in Ahmedabad, India. The crash involved a Boeing Dreamliner bound for London, and the incident killed more than 240 people. This incident is truly devastating, as are all the incidents that have occurred and resulted in injury and loss. Our thoughts and prayers are with the families of the victims of this incident.

We hope by bringing an analysis of recent incidents to light, fewer tragic accidents will occur in the future.  We believe starting these honest, open conversations is Step 1. We urge all safety professional to take learning from these events very seriously – there is no progress without an honest review and reflection of the past.  

The latest episode of Failure Files on Pipeline Things discusses the breakdown of barriers that led to two Boeing plane crashes. These devastating accidents raise questions about cost pressures impact on safety culture and the role of regulatory oversight. Rhett and Christopher discuss how the aviation industry was pressured to give approval, and how this story serves as a cautionary tale for the pipeline industry.

Like many of the failures discussed in this series, it is difficult to name one “bad actor” that enabled these tragedies. In truth, these events are the culmination of many different barriers breaking down under a complex network of business incentives. By arming ourselves with the ability to identify these influences, we are better prepared to make safer decisions in the future.

Highlights:

  • Factors and outcomes of the two incidents
  • Regulatory processes and blurred lines between safety and a race to revenue-generating business
  • Lessons learned for pipeline safety regulatory processes

Connect:   

Rhett Dotson   

Christopher De Leon   

D2 Integrity   

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Pipeline Things is presented by D2 Integrity and produced by FORME Marketing.    

D2 Integrity (D2I) is providing this podcast as an educational resource, but it is neither a legal interpretation nor a statement of D2I policy. Reference to any specific product or entity does not constitute an endorsement or recommendation by D2 Integrity. The views expressed by guests are their own and their appearance on the program does not imply an endorsement of them or any entity they represent. Views and opinions expressed by D2I employees are those of the employees and do not necessarily reflect the view of D2I or any of its officials. If you have any questions about this disclaimer, please contact Sarah Etier at [email protected].   

  

Copyright 2025 © D2 Integrity  

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Episode Transcript

Rhett On this episode of the failure files, Chris gets exceptionally excited about a non -pipeline related industry failure. And it's one that has broad application to all of us. If you have flown on a plane this year, will fly on a plane this year or will fly on a plane in the next couple of years, the incidents related to the Boeing crashes with the 737 MAX are both familiar and personal to all of us that fly in the United States. I think the relationship to pipeline integrity is also very clear. And so as we dive into the influence of profit motives, I'm really inclined to remember a statement that's close to heart, which is integrity is not negotiable. I think you'll really enjoy this episode and learn a lot. Thanks for joining us. All right, on this episode, we were kind of far. We kind of missed that episode of Pipeline Things, where we continue our series on the failure files, part two. We're gonna be at another one. This failure, or this incident, I think, is recent enough for all of our listeners to participate because it's less than seven years old. So, And most of us probably remember it. If you travel a lot, you probably think about it. I know that I do for sure. Chris Well, you mentioned like in our last one before story time with Rhett starts, you said, you know, when I was in college, you know, the challenger issue didn't really hit that close to home. There's probably a lot of still people who weren't really in tune with the news when they were in college. And maybe a lot of this happened and they weren't fully aware. Rhett I'll tell you what, given how much you and I fly, this one's in tune to me. Like I find myself it's terrible, But I find myself checking the plane every time now when we fly I'm like. Chris Dude after this happened I absolutely was doing this Do the Airbus 319 is nice. Rhett Really nice and so now the audience you probably figured out where we're going which is we're going to be talking about the the Boeing incidents that have happened recently. So in order to do that I want to set the stage for you. So we have to go back through to 2018. That's actually where the story starts. So in 2018, we had just come off of the safest period in commercial aviation history, right? They had no large aircraft incidents in that prior year. And then all of a sudden we have not one, but two plane crashes that occur in short order. And I'm gonna bring you through both. And then we're gonna, so what we're gonna do this is I'm gonna set the stage for the two incidents. Then I'm gonna backtrack in time and talk about what actually led up to the incidents. How do we get where we are? So the first is Lion Air 610, which is a flight from Jakarta. And that happened on October 29th, 2018. And the plane is brand new. So the way this goes on is that the airspeed low alarm is triggered, the flight then dives straight into the ground 13 minutes after taking off, killing all 189 people on board. Um, what's interesting is the initial reaction in the days after basically blamed it all Lion Air, right? It was like, Hey, this is a discount carrier. Um, as an aside note, when I say that it was a discount carrier, there is actually banned from flying into the US because of safety issues. So it made it, it made it very easy in the immediate aftermath when the incident happens, uh, while people were questioning hey, this is very unusual and they were looking towards Boeing. It was very easy for Boeing to deflect and say guys come on. This is Lion Air. Like do these guys really know how to fly the plane like what's going on, right? Um as they begin to get more information that story falls apart, so they they capture the black boxes which the fun fact is that the black boxes are actually orange not black. Um, showed that the plane had a faulty angle of attack sensor, right? And so what the angle of attack sensor is, right? It's when the plane takes off. You ever looked when we get on the plane, you see the two little pointy things that stick up? Those are the angle of attack sensor, right? Chris And so they-- - Isn't there a show that's like orange is the new black and has something to do with jail? Rhett - Yeah, I don't know if that has anything to do with these black boxes, but I'm just saying the black boxes are orange, right? So the angle of attack sensors measure the nose of the plane during flight and then multiple alarms went off and all sorts of things kept going on and so what would happen when the pilots were flying this lion air flight is that they kept pulling the nose up and then something keeps pushing it down and so when you look at the actual trajectory of the flight it goes up and down up and down till eventually it crashes into the ground right so at some point after the the lion air Um, people are like, Hey, this, this wasn't a pilot issue. What's going on? And Boeing says, Hey, uh, there's an issue with the MCAS and universally the pilots, the whole industry's like, WTF is an MCAS that is their first reaction. They'd never heard this before. There's actually a famous story where like the head of the pilots organization had to flip open the manual for the, for the new Boeing 737 max and he had to go in the only place he could find MCAS was in the abbreviation section where it said MCAS is the maneuvering characteristic Augmentation system. They're like, what is this thing? Right? So while they're looking into it Basically, they find out that Boeing had implemented something because of the way the plane was designed and we'll get into it in that a moment At certain air speeds the the MCAS system would basically push the nose of the plane down to keep it from stalling out. There were certain conditions where if the plane's nose was too high, it would stall out. If a plane stalls, it goes straight down. So the MCAS would basically take over and then push the nose down. But nobody had ever considered what would happen if the angle of attack sensor was incorrectly reading. So if the angle of attack center sensor is feeding the MCAS bad information, what happens? And that, that scenario had not yet been considered. So when all this kind of comes out, Boeing basically says, Hey, look, look. Again, the pilots had the ability to shut off the MCAS system and they didn't do it. And they, Boeing squarely points the finger at the pilots. Now what's really interesting is the pilots on the flip side totally flip out over this. Like in the United States, pilots kind of rattle around each other and they're like, no, we never even heard about this. What is this? These pilots weren't trained on this and they start blowing up. And they were actually calls at this point in time to begin grounding the 737 MAX. But Boeing comes back and says, hey, we're gonna fix this in six weeks. We're gonna give out a software fix. Well less than five months later. There is no software fix if you're curious five months later So six weeks timeline didn't happen March 10th 2019 Ethiopian Airlines flight 302 crashes six minutes after takeoff killing all 157 people on board again. It's a max eight aircraft Initial reactions Boeing does the same exact thing. They continue to push back on placing Any blame and what's what's this is where it gets interesting the FAA Also refuses to take any action. FAA is like look, we don't have enough data to do this Meanwhile, everybody else in the industry is like guys we've had two planes fall out of the sky under perfect conditions. No weather events same exact plane Then you actually if you looked at the trajectories even in the days after the like nearly the same trajectory that the lion air and people are like, guys, this is obvious. So guess which country is the first to ban the max eight? Chris I don't want to guess Rhett China. Chris I was going to say had to have been us, had to have been us, right? Rhett So what really crazy note is China is the first to ban the max eight and then numerous other countries fall suit, right? And they do it on the basis of looking at that initial flight pattern data that immediately after they get the black box And then the most damning evidence is that they find the jack screw So what the jack screw is is on the the the the angle some little flappy things on the back of the aircraft What the MCAS system would do is when it was sensing it was nose up It would jack those down to pull the flame down They found that screw all the way in the bottom most position like down and so people were like, oh, this is a hundred percent got to be related to the software in the MCAS. This is actually a systemic error. This isn't a pilot error. This isn't this is a Boeing plane problem. Chris Something was jacked up with Boeing. Rhett And this is where it gets crazy. The FAA still has not grounded the flight. Guess who grounds the Boeing Max 8? Chris Somebody needed to make America great again. Rhett President Donald Trump, first time around, not second time around, is the one, and this is unprecedented in U .S. history for the president to be the one to ground the planes, not the FAA. Chris Unprecedented. Rhett Yeah, this was, you know, you can look at it. It was a presidential unprecedented decision. Um, right, and so after they begin hearings on the thing. Boeing continues to blame the pilots. They like they Boeing continues to maintain the stance that it wasn't their fault, even in the aftermath. But unfortunately, when they analyzed uh the black box data, it shows a different story. So you remember that Lion Air flight, they said, the pilots were supposed to shut off this little thing. And they should have done that. Well, this time around, when they went back and analyzed it, the Ethiopian pilots had done everything they were supposed to do by the book and the plane had still gone into the ground. And it was at that point where people, like the pilots association in particular really got upset and they really began to take a hard look at Boeing and the MCAS system and what was going on. So now that you know it was the MCAS system, and it was an unsafe system. So let me give you, again, what happens here is this system literally takes over the plane and points it nose down when it thinks it's about to go into a stall situation. So how did we end up in this situation? Chris That's what I want to know. Rhett How did we get here? Well, if we're going to do that, we've got to go further back than 2018. We've actually got to go all the way back to 1990. Chris And it's quite curious if I can jump in just briefly because I mean, obviously the airline industry is real big on information sharing and lessons learned. Rhett Yeah. Chris Right. So generally, we have this, this perspective of this industry is safe. Rhett Yes. Chris Right. And so there's transparency, there is lessons learned, there is collaboration. What happened? Rhett And how did an industry that was so renowned and Boeing like Boeing, if you would, it's like the shining star of a safe organization. How does, I'm gonna say like a pinnacle of American excellence, if you will, a pinnacle of safety find itself in the center of a discussion around an unsafe design. And this is the point in the story where again, I want the audience to appreciate there are elements here that are criminal and Boeing suffered criminal convictions. I really want to separate the criminal aspect from the decisions that led to how we got here, right? 'Cause there are engineering, and as we're gonna see very real relationships between regulators and financial pressures that lead us here. So um you have to go all the way back to 1996, Boeing merges with McDonnell Douglas, right? And so historically before this, Boeing was a nerd company, an engineer first company, and McDonnell Douglas was a stock centric shareholder return centric company. When the two of them merged, people noticed an immediate cultural shift because McDonnell Douglas was more savvy in all of the negotiations and got their VPs put in charge of the company. So you have this huge cultural shift in Boeing where you go from being a nerd first engineer first company to a shareholder price driven returns, minimalization type company, and people start to feel the effects of that almost instantly in the most notable way that this happens is the engineers start to complain about issues that come up quality issues and engineers not being paid attention to when McDonnell Douglas or Boeing does. What Boeing does is that The engineers and the VPs had always been in one place in Seattle, like they were in the same building. The engineers were literally right outside of all the offices. Chris Please tell me they separated them. Rhett Boeing picks up all of the executives and moves them to Chicago to insulate them from the feedback from the engineers, right? Chris So who needs transparency? Rhett No decision more adequately describes what was happening culturally within the company, then the decision to pick up and move all the executives away from the complaining engineers into Chicago, right? But then some other things happen, right? So Boeing had always had the largest amount of market share, they were the giant in the room, if you will. Well, the newcomer comes up and starts taking market share and that newcomer is of course Airbus, right? And So what really, really pushes the situation to the breaking point is that Airbus introduces their new A320 Neo, right? And that plane was gonna take a lot of business from Boeing and Boeing had nothing to compete with it. Like fuel efficiency wise, it was gonna be better. And so Boeing starts losing customers. And what's interesting about their industry is that these orders take place years and years in the future. So people come in, they're like, Hey, I know I'm a longstanding client of yours Boeing, but I'm ordering 100 planes from Airbus next year, not from y 'all. So Boeing can see this happening, right? Boeing immediately comes out and says, we will produce a redesigned plane. And they gave their, they had to do it with the 737, because they didn't have time to build a plane from scratch to build a plane from scratch is multi the plane that ultimately becomes the one from scratch is a 787 Dreamliner. We didn't see the 787 Dreamliner come out for a long time, right? They have to do something in the short term and they have to do it with the 737 max with the on the only way to get a 737 to pair up with the Neo was to put newer and bigger engines on it. But when they put newer and bigger engines on it, it causes some aerodynamic changes that lead to a performance in the way that the plane flies, right? So in a few specific scenarios, by having these massive engines so far forward on the wing, it created situations where the plane was now unstable or would stall out. What Boeing recognizes is, oh, because of our work in the defense industry, we develop This maneuvering characteristics augmentation system to solve a problem on fighter jets, we can take that software solution and bring it on to this, this new 737 max problem solved. Chris Makes me think a lot of a segue, right? How you can lean into it and then it has controls and motors that balance it. And so if you get the right frequency of change and control and has enough power, it can make you feel like you're steady. Rhett Yes. What's, what's critical about this change though, is that the purchasers of the aircraft put one more additional constraint on Boeing. They said, if you're going to build us or offer us a new aircraft, I cannot require me to train my pilots because that's the second biggest, next to aircraft, the second biggest expense that the airlines have because not only they They have every time they train their pilots. They have to pull those pilots out of service go send them somewhere and pay for it So all of their clients say look you can give me a new aircraft, but you will not have New client training. Chris God this this is so bow. This pair this parallels the I like business So closely Rhett don't don't deliver the baby yet. I want the audience to fully appreciate what Chris I hope all of you already know Exactly how this parallels Rhett what What happens? And this is crazy. Boeing goes to great lengths to hide the degree to which the MCAS actually functions, right? And they go to great lengths to confuse everybody about what it is. And this is where I say that you have to divide them. The criminal elements from the cost pressures, right? You've got management putting cost pressures down on Boeing, which are very real. Boeing's like, look, man, we, we can't do nothing. To do nothing means that Airbus gets all the thing and then none of us have any jobs. So management comes and says the engineers, you will do this. The engineers then come up with a solution. And then people use interpretation mechanics to figure out how to get it past the regulators. And it's like in one example, when the FAA comes in to hear about this new proposed 737 max and give it its approval, The engineer in on purposely creates a presentation that is so complex and filled with so many charts That he knows the FAA represent in charge cannot follow it and he does it intentionally Like chalk full of the most engineering and just spends all this time and so they you know the FAA representative is starry I don't know the end of it. Absolutely, right and the FAA unfortunately, because of resource constraints on their end, had taken, they had measures in place, like there were incentives on the FAA side to speed up regulatory approval processes that had been put in the Reagan era of deregulation in order to ensure that aircraft production wasn't held up by regulatory processes that created unfortunately a negative control loop for the regulators to then want to approve things in the interest of speed. Chris We've seen this also in our space. Rhett Thats how the MCAS system gets on board. And then obviously the real point of failure was you had a single, you had this MCAS system, which, which this is what's mind blowing. The entire MCAS system relies on data from that one sensor you've seen that little sensor on the plane right I told you about it. Chris What are you supposed to sit is right over the wing? Rhett No, no, no, it's not on the wing. It's on the nose. Chris Oh, sorry sorry yeah yeah yeah yeah Rhett right underneath the Chris Yeah yeah yeah Rhett To my audience next time you get on a plane look right look just underneath where the pilots window is look down You'll see that little sensor. Hey, there's two of them one on either side the MCAS data relied on one if you talk to pilots So like, Oh dude, those things, you hit a bird, that thing breaks off. If you get a plastic trash grocery bag that accidentally covers the sensor on takeoff, it will feel like these are notoriously like spotty sensors with issues. And that's what the MCAS system relies on. Chris Sounds like an odometer wheel a little bit. Rhett I think it actually is probably maybe as likely as an odometer wheel, but maybe even more important than an odometer wheel to fail. And so that's how this story puts together, right? So I wanna pause to the honest to recreate. You have a situation where Boeing as an industry is facing tremendous cost pressures. And look, I don't wanna understate Boeing's pressures. To the extent they're laying off hundreds of people if they lose all this business to Airbus, you have engineers who are given a problem to solve and told you will solve it. They come up with a solution and the engineers, look, the engineers raised objections to this. Like there is a whole backlog of engineers that did their jobs within Boeing and said, you need to be aware of this. We can't do this, we shouldn't do this. If we do this, you must do that. Chris Just 'cause it goes on a fighter jet doesn't mean it's gonna fit on a commercial airline. Rhett Exactly, Boeing goes to great lengths to conceal the extent by over technicalizing it, to hide it from the FAA so that ultimately they can get the airplane pushed through without any training. The only training that they were required to watch was a PowerPoint presentation provided by Boeing, right? And so ultimately the pilots are inadequately trained, they don't understand this MCAS, they don't understand the power that it has to take over the aircraft, and obviously the end results. Chris Can we, are we ready to unpack this? Like, I'm on the edge of, I'm ready, I am ready to unpack this. Rhett But I'm gonna come right back, and we're gonna let Chris unload. Hang on, we'll be right back. - Giant fireball there. Break Rhett So we're back on our episode of failure files with Boeing and I set the stage for you guys with what happened, right? So just to recap under tremendous pressure from adversaries or, I'm sorry, not adversaries, competitors who had designed a new aircraft. Chris Sometimes they are adversaries. Rhett Yeah, that's just true. Boeing, it produces the 737 MAX and really kind of conceals a tremendous extent to which the MCAS system played a role and allowing that plane to safely fly leads to two incidents killing over 300 people. And, you know, that was what we reviewed in the first part. Chris has been jumping out of his chair, like on the edge, wanting to make parallels to the pipeline industry. And so, Chris, I want to start with the first one. And I want to set the stage for that, which is the resource constraints and the profit motives that exist, right? Because this is real to our industry. So like just to help you guys appreciate the significance of the profit motive and the demand. Even now, Boeing's order books are full for years to come. Like you don't just buy a plane this year and get it next year, right? The backlog on plane production is currently predicted to last 14 years if they don't manage to increase rates of production. So that puts tremendous pressures on the part of Boeing to get planes out the door and get the planes out the door that the customers want, right? On top of that, Boeing can't just sit back in the face of the A320 coming out and being like, "Well, yeah, they got a better plane." Ours will come out in four or five years. "We'll be good. "We'll just wait four or five years, "lay off hundreds of people, maybe go out of business, "but we'll have the plane, right? "We'll do it the right way, right?” Chris? Chris Yeah, my first reaction is, we talked about the challenger incident. And in the challenger incident, you said something, you said space race. Right? And when I think of race, depending on how you approach it, it makes me wonder, it doesn't that challenge safety culture? Right? Right. I mean even like in an F1 race, right? Like it's there's high risk and you always do some compromise, but at the end of the day It's it's a bunch of nerds was the example that you gave to Boeing, right? These were nerds these were guys are about the science and building cool stuff that worked kind of like the heart of engineering, right? And I feel like there's a pretty big parallel here, right? So there was a change in market forces and there's kind of a race. And decisions need to be made. And the decisions that were made weren't technically sound, they were more motivated by profits and more manager decisions. And the parallel I begin to see in our space, Rhett, is it's not a one for one. But I mean, There's already a lot of pressure on online inspection companies, if we're going to talk about that a little bit, and that the backlog for Boeing was on the order of years. But how does the normal project lifecycle and budgeting happen in our space? It's like a year, right? Backlogs are a lot shorter, so decisions and defending your market share and gaining market share is significantly more competitive. So anytime there is a new technology or a change in service, the response, the agility, the planning and action for an ILI company to stay profitable or to maintain market share is so dynamic. It's a perpetual race. Rhett No, that's true. I mean, once one company comes out with a technology, you see people that are trying to match that technology, or, you know, it's not, I've made the joke before, and Bruce Nessleroth said it too. It's not by accident that almost all the specifications are identical. It's not practical. It's not statistically possible that all the specifications should be identical. Chris But that just became the standard, which is now a sales approach versus it being technical. It's a market force almost in itself, right? And so if the budgeting and the sales cycle in itself is already a race, it can be further compounded if we think about it, right? And it makes me think and not saying right or wrong, we're just, I think it's a fact, right? The ILI space has become very attractive because of federal regulation, the number of mileage, the aging infrastructure. And so we've started seeing a lot of investors look into our space, right? And so we'll start seeing private equities or companies in the stock market looking and saying, hey, there's a lot of opportunities here. And man, that really starts to parallel what you said happened to Boeing, right? Rhett Yeah. So it's interesting on me. So you draw that on the ILI side, right? So I do think there's a tremendous difference when something is privately owned versus when it has very real stock market or I'll say private equity pressures acting on it. But I mean, we could draw the same pressures on the operator side, right? And that's what I'll say. So what this brought to mind for me was the book California Burning that Ginny DeGrease had recommended. And that book was excellent because it sets the stage for, and it talks a lot about the PG &E failure. But what it does is talk about the fact that, hey, integrity is viewed as an expense. And so on the operator side, if you can save 10% on an expense, it's just money saved. But it gets a little worse than that because on capital projects, they get a return on capital projects with at least 10%. So if I can save money on the integrity side, spend it on the capital projects side, I can actually take that money saved and turn it into a bonus. And in that book, "California Burning," she talks about the fact that like, that's like a death spiral that it creates 'cause you have an endless incentive to minimize integrity. And I think those integrity pressures on operators are very, very real, right? They're, we're challenged to do more with less. We're challenged to do more inspections, maintain more mileage. And to do that with the same resources or maybe even less resources. And that for me mirrors this. Chris What ultimately is going to happen is that we have to start thinking about how much gravity does the cost pressure have on someone in integrity role deciding on which ILI technology to run. Rhett Oh, it's a tremendous amount. No doubt. I mean, budgetary pressures on the ILI side are very real, right? I mean, that's why they put ILI projects out to bid. Chris Yeah, which in turn makes it more... If we're not careful, it can feel more like a sales -driven practice for a decision -making process versus a technical merit, right? I use this system for X, Y, and Z. Not, well, the specifications are the same. And so which one of these has a better cost value, right? And again, that whole idea of a cost value can in itself be pretty comprehensive, like, okay, well, how many digs did you have to do and what about level of service, et cetera, et cetera. We appreciate that. We're saying at a macro level of the analysis. And a derivative of that, which I see here, was the approach in not paralleling this to ILI in itself. The question that I'll bring here is an understanding of the technology and the change, right? And so maybe you were gonna ask me, but I'll ask you, Rhett, what are your opinions on what level of an understanding do you think was merited when the system changed, when an essential variable on a system changed? What level of understanding should the regulator and /or the operator, or in this case, the airline, what level of understanding do you think you should have had in that change, right? Rhett You know, I think this is a challenge, Chris, 'cause I'm trying to think about it on a personal level, and we buy products all the time without an adequate understanding, but that's on a personal level. So when a system is too complex for a user to adequately be able to understand the depth of it, I mean, I think about, you get upset because I let my car auto -drive, right? It drives you nuts, but I freaking love it. Chris Put your hands on the wheel now. Rhett Do I understand exactly how my car auto drives? Like maybe there's a couple of cameras. A couple of cameras, radar sensors. Chris Some algorithms. Rhett But no, definitely don't understand the depth of the algorithm. Chris Automatic feature searches from image to neighboring vehicles. Rhett So, but I would hope that somebody before that system was put in, looked at it and I think that's why we rely on really government regulatory and approval and we have things like safety recalls on vehicles. Chris So you looked into that. You looked into the regulatory requirements for the Superdrive capability of your car. Rhett I'm making a parallel here. Chris Or you're just saying GM is so good that I trust them. Rhett I'm just making a parallel here. And the reality is that I think, I don't know that I think the airlines have to be responsible for understanding exactly how the plane is certified and changed, right? So at the airline level, they purchased a product and they expected the product to meet certain requirements. The only two safeguards you have against that are hoping that Boeing will do what's right. And as we've seen time and time again, that in the face of profit money motives, companies often won't, or that the regulators catch it. And in this instance, the regulators had no ability whatsoever to be able to understand that. I mean, Boeing went to great lengths to make it more complex than the regulators could understand. I think in our market, Chris, that parallel is very real. I think we ask PHMSA with basically a skeleton staff to audit operators' processes that are many times too difficult for them to understand. Chris Very complex, I think is the appropriate word, yeah. Rhett And, man, I mean, in that instance, you have to fall back on trusting that the operators processes are checked, right? Chris You know what it makes me think of, Rhett, you know, I'm gonna jump in if you don't mind is one of the constraints that the airline put on Boeing was related to training. Rhett Yeah. You can build a, so you could sell us this aircraft, but it cannot have additional training requirements. Chris And we understand that the regulatory body is PHMSA in many cases. I mean, there's also state regulators, but let's just, again, to keep things simple. If there's new regulation that allows for the use of ILI in various cases, bit of a rhetorical question here. So what training should be required of the inspectors on each of those technology types? And again, not that we have to answer, but I mean, it just it begins to bear the question, right? Rhett That's fair, right? So we talk a lot about competency in our industry on the operator side. This this does beg into question. This this really, really should we have competency requirements for regulators? I mean, Look, I've never considered, I don't think I've ever had anybody ask me that question. I would 100 % be in favor of training for regulators to understand the depths and processes of ILI and how it actually works. I mean, I think, look, man, listeners might get upset with me here because the reality is, I think the more informed and educated the regulator is, the better and safer our industry is 100%. Chris And it's not... We're not ignorant to the fact that there is a lot of training that happens. Like, let's be really clear. And we know that there is ILI -specific training that happens to be clear, right? And that, you know, our friends, and I'll say it that way, right? Because We are a community that are all with one goal in mind, which is pipeline safety, not integrity, safety, right? Integrity is a part of that. We find them in technical meetings with us all the time, right? And they ask questions and they're involved and they're, they're exposed to right information. But that's not the question I was asking, right? The real question was not is training available, but it's like, what is that management system beginning to look like? If it's a safety culture, right, not a process, what level of training would be required? Because, and let's make it specific, right? We now have MEP reconformations via ECA. And it doesn't specify which ILI technology you have to use. It specifies which threats you have to address. Well, how many ILI technologies out there are specific to specify those threats? I mean, to address those threats. And then I want to allow the layer of complexity. Rhett So I mean, in that example, they rely on if vendor A says I can address this threat, they're relying on vendor A, both being responsible and truthful in their ability to address that. Chris It's much like the FAA with Boeing, right? And that they kind of trusted that Boeing, Boeing had, you know, safety, you know, personnel on staff that did certifications. It's the whole component. But then I also think if I'm not mistaken, that's kind of like outsourcing safety, right? Self -governance and you've heard me say this time and time again, the ILA industry is allowed to self -govern. The only consequence they have are lagging indicators related to revenue and consequential damages related to if there was a failure, is there any type of lawsuit or something like that? But it's all lagging, right. It's not leading, right? It's not before I deploy this system, this ILA system that is provided by this service provider back to what level of training should the operator and the regulator have before we begin to instill the the duty of care like Mr. Yawks always like to say that this HCA based pipeline where there's homes we're gonna rely on this ILI system to help to ensure that that that that pipeline can safely transport whatever medians in it? Rhett Yeah, I mean, man, like, I think if we could solve that question today on this podcast, it would be amazing. Chris This podcast would be memorialized. This episode would have the most views ever. Rhett Yeah, it's it's a fair question because I always look at what what barriers exist there, right? So on, I mean, and it's a fair question to say, there, there are profit motives and cost pressures that that will push ILI vendors to produce and promote products and take on work that can put them dangerously on the edge of what they can competently produce, right? That's natural because more work, more dollars, more returns, happier investors or happier owners. That's real. Chris Hold on. And an ability to create new technologies which we need and improvements. Rhett On the flip side, you have pressures on, you would hope that your checks there or that you have a specification and that the operator or the vendor meets that specification and that the operator is holding them accountable to that specification. But then that goes with the operator has to have the resources in the training to understand how to hold them accountable to that specification, that the operator has the support for their integrity engineers to be enforcing that specification and competency to address that specification. So it's really on both sides, because then on the organ of the operator side already mentioned, you know, they're under constant pressures to do more with less, right? So how does it how does an integrity manager at an ally company fight to get the budget he needs to qualify ILI vendors, right, and train up his integrity engineers to qualify an I like an operator. Chris An ILI operation operator. Rhett Yes, I'm sorry. Those are very real problems, right? Um, and, uh, man, I don't, I don't have the answers. I think the key there is that, I mean, Chris, we have to recognize that largely we're an industry that relies on people doing the right thing and having safety at its heart. Like that, unfortunately, I'd say that's probably our, our largest and most porous barrier at the same time. But we have to rely that we have good people doing jobs that want to do the right thing. And sometimes profit voters win. Chris Yeah, and then, and again, we keep saying it, right? Maybe, maybe that-- - Rhett But we should do better. Chris - Maybe that-- Rhett - We should do better. Chris Maybe that conduit is pipeline safety management systems, maybe, right? And until then dig, dig, dig, dig, dig. Rhett So, um, again, this episode, I really want to, um, man, the hard thing about this Chris is, and I hope the audience can sense this in our industry. I feel like almost always I see the right people doing the right thing, right? And I see like the general things people want to keep pipeline safe, the desires to keep pipeline safe. I don't see many bad actors. And that makes the challenge in an episode like this, is I just want to bring it home for everybody. There were bad actors here. There were people that did things deliberate, but the motives that made them do those things or pushed them to do those things exist in us. So my ask to the audience is, check yourself, like we used to have somebody that would say, he would sign all of his emails. I don't know if he's a listener or not. And his signature was integrity is not negotiable. Integrity isn't negotiable, right? If there's one thing the failure file series will be taken away, the cost pressures are real. If you don't feel like you have the adequate understanding, dig in. If you feel like you need more information, dig in, right? Ask the questions you need to keep the pipeline safe. That's big takeaway. Um, and yeah, maybe we should have training for our regulators Chris But hold on, but to be clear, it's not, this is not a knock on the regulators Rhett No it’s not because they have to do more with less too Chris Because equally again, and equally the question was to regulators and the operator, right? When the ILI bid goes out and they got all these, all these technologies, right? The question then bowls down to, I mean Rhett How many ILI operators were offered voluntary leave where like half the force took it? (laughing) I don't know what the outcome of that will be by the time this episode airs, but there you go, there's a timestamp, right? But that's very real. Chris We're not ILI operators, we're other regulators. Rhett Yeah, the regulators, right,cthat's my point. So how many ILI operators were offered that? Like we don't seecthem cutting their force reductions in half, but you do see PHMSA struggling with the weight of voluntary force reductions there. That's real, so. Chris That's valid. Rhett So to our audience, again, I'm gonna wrap it up. Hopefully you enjoy these stories. Hopefully, again, my ask is that you see yourself in them. And by see yourself, I mean that you can empathize with the situations and that you can recognize that feeling maybe in you when you feel that pit, like, oh God, that's a cost pressure. And you know it's not on the same line as integrity. Being aware, I think, is absolutely the first step. And then from there, hopefully you can remember some of these lessons. And as an industry, we can get better and do better. And that's our goal to learn from previous failures. So again, really appreciate you guys taking the time to join us. Hope you enjoyed the show and look forward to talking to you again soon. Rhett This episode of Pipeline Things was executively produced by Sarah Eteir and written by myself, Brett Dotson. Source material, which I encourage you to look into, if you would like more information, is the Netflix series Downfall, The Case Against Boeing, and the American Scandal podcast series entitled Boeing.

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