Digital Feature: The Standards Development Process-Part 2: Drafting and Consensus Building
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.
