Tracking and Traceability in Plastic Gas Distribution Systems- changes and challenges in technology

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1 Proceedings of the 17 th Plastic Pipes Conference PPXVII September 22-24, 2014, Chicago, Illinois, USA Tracking and Traceability in Plastic Gas Distribution Systems- changes and challenges in technology Randall J. Knapp Plastics Pipe Institute Irving, TX, USA ABSTRACT The Pipeline Inspection, Protection, Enforcement and Safety Act of 2006 required the Department of Transportation (DOT) to establish a regulation prescribing standards for integrity management programs for distribution pipeline operators. The Pipeline and Hazardous Materials Safety Administration (PHMSA) published the final rule establishing integrity management requirements for gas distribution pipeline systems on December 4, On August 2, 2011 Distribution integrity management program (DIMP) was implemented mandating that gas utilities have integrity management plans in place for all gas products to improve pipeline safety. Operators are required to know what s in their pipeline system. To support that effort many of the ASTM gas pipe and component standards recently implemented tracking and traceability requirements for gas distribution pipes and components that require encoded (barcode or alphanumeric) information to be printed on the pipe and fittings in a manner that can be used by the utility customers at the time of installation to facilitate their particular tracking and traceability systems. The implementation of tracking and traceability efforts for plastic gas distribution system components represents a major industry investment in capital and education. The challenges of implementing the product standard marking requirements during the manufacturing practice of plastic gas pipe and components including: printing and labeling technology, marking permanency, and data transfer, have yet to be fully designed and implemented by all manufacturers. The technical difficulties in the manufacturing process coupled with widely varying tracking and traceability system demands from large and small operators has slowed the implementation of an effective tracking and traceability system. It will be necessary to apply new technologies in printing, scanning and data collection to fully implement reliable tracking and traceability systems across the industry. INTRODUCTION The Pipeline Inspection, Protection, Enforcement and Safety Act of 2006 required the Department of Transportation (DOT) to establish a regulation prescribing standards for integrity management programs for distribution pipeline operators. The Pipeline and Hazardous Materials Safety Administration (PHMSA) published the final rule establishing integrity management requirements for gas distribution pipeline systems on December 4, On August 2, 2011 Distribution integrity management program (DIMP) was implemented mandating that gas utilities have integrity management plans in place for all gas products to improve pipeline safety. Operators are required to know what s in their pipeline system. To support that effort many of the ASTM gas pipe and component standards recently implemented tracking and traceability requirements for gas distribution pipes and components that require encoded (barcode or alphanumeric) information to be printed on the pipe and fittings in a manner that can be used by the utility customers at the time of installation to facilitate their particular tracking and traceability systems. Also, a website created by PPI under license from OTD (ComponentID.org) now allows manufacturers to register their company's two character ID s so they can more readily provide traceability information that gas utilities can use in their implementation of DIMP. 1 Copyright 2014 by PPCA

2 The implementation of tracking and traceability efforts for plastic gas distribution system components represents a major industry investment in capital and training of the entire gas distribution supply chain. This paper will review the changes and the challenges of implementing DIMP and various product standard marking requirements during the manufacturing practice of plastic gas pipe and components including: printing and labeling technology, marking permanency, and data transfer. In addition, the paper will address the current technologies in use, those technologies being considered to comply with the new requirement, and future directions. The Changing Gas Landscape Regulations and Compliance As noted, over the past few years regulations have been driving the need for additional asset tracking & traceability on plastic gas distribution systems. While DIMP is a broad program that is administered by PHMSA, there are 7 key elements of the DIMP Rule: 1. Develop and implement a written IM plan. 2. Know the infrastructure. 3. ID threats. 4. Assess and prioritize risks. 5. ID and implement appropriate measures to mitigate risks. 6. Measure performance, monitor results, evaluate the effectiveness and make changes as needed. 7. Periodically report performance measures. The heart of the DIMP process is for operators to know their systems and know the risks. Increased scrutiny spurred by public incidents along with federal regulations have put gas operators under increasing pressure to improve data collection and records, and to know their distribution system in order identify all components and develop suitable maintenance and replacement efforts. A large part of that effort entails standardized data collection and reporting to simplify the process. At the same time proactive operators and manufacturers are leading the change to improved asset tracking and safety, and have already implemented coding technologies on their products and systems. The systems range from basic ink jet printing and manual data recording to laser markings and barcode scanning. Many have realized that while electronic data collection versus manual data collection, may add to system complexity, it can allow for improved accuracy and efficiency. While gas operators are required to document a plan for knowing their systems, they are currently not required to use a standardized tracking and traceability system. Nor is there a mandated deadline for implementing standardized gas product coding systems, such as ASTM F2897. While currently unregulated, it is anticipated that standardized tracking and traceability of gas distribution system components will become codified in the near future through PHMSA regulations. The expectation is that plastic pipe regulation will lean heavily on standardized approached such as ASTM F2897 marking requirements. Standardized Product Coding The ASTM F2897 initiative was intended to be another tool that enables operators to know what products are in their system and where they are located. The definition and breakdown of ASTM F2897 follows for informative purposes. ASTM F Standard Specification for Tracking and Traceability Coding System of Natural Gas Components (Pipe, Tubing, Fittings, Valves, and Appurtenances) has become the defining standard for the standardized coding methodology for gas pipe and components. 2 Copyright 2014 by PPCA

3 The scope of ASTM F2897 defines requirements for the data used in the tracking and traceability base- 62 coding system (0-9; a-z; A-Z). The final output is a 16-digit alpha-numeric code that defines certain characteristics of gas components. The 16-digit code can be reproduced as print line or standard barcode. The Standard is published and included within associated gas product standards. A summary of the code content is provided in Table 1. Table 1: ASTM F Code Content Summary (downloaded from PPI Energy Piping Systems Division website, June 18, 2014) INPUT DATA DESCRIPTION CONVERSION EXAMPLE OUTPUT CODE COMPONENT 2 CHARACTERS ASSIGNED NONE 2 CHARACTERS MANUFACTURER BY PPI MANUFACTURERS 7 DIGITS ASSIGNED BY THE USE BASE 62 TO CONVERTS 4 CHARACTERS LOT CODE MANUFACTURER TO UNIQUELY REPRESENT CONVERT THE 7 DIGITS TO 4 TO 5BAN THE PRODUCT. CHARACTERS PRODUCTION 5 DIGITS REPRESENTING USE BASE 62 TO SEPTEMBER 1, 2012 = 3 CHARACTERS DATE THE DAY OF THE YEAR (3 NUMBERS) AND THE YEAR CONVERT THE 5 DIGITS TO CONVERTS TO 6NM (2 NUMBERS) CHARACTERS COMPONENT 1 LETTER REPRESENTING NONE B = PE LETTER MATERIAL THE MATERIAL E = PE4710 DESIGNATION COMPONENT TYPE SELECT FROM TABLE 4 OF ASTM F2897 NONE COILED PIPE = 12, WELD END 2 CHARACTERS TRANSITION FITTING = T1 COMPONENT SIZE CALCULATE USING USE BASE 62 TO 4 IPS DR 11 X 2 IPS 3 CHARACTERS EQUATION 1 AND TABLES 5-7 FROM ASTM F2897 TO CONVERT THE 5 DIGITS TO 3 SDR 11 = = 3KP OBTAIN 5 DIGITS. CHARACTERS CURRENTLY UNUSED 0 NONE 0 1 NUMBER The minimum requirement for barcoding is a Code 128 standard barcode format that may be expressed in 1D or 2D. Other barcode formats can be used, however they may be a special addition and the product manufacturer should be consulted. According to the product standards that reference ASTM F2897, all products must also be marked with a 16-character alpha-numeric code in addition to the barcode. This alpha-numeric code can be manually recorded with installation records in cases where electronic data collection is unavailable. The resulting code generated from ASTM F2897 can take the following forms: 3 Copyright 2014 by PPCA

Code 128 Barcode 16-character alpha-numeric code 2D Data

traceability identifier call out a unique manufacturer s code.

company's two character ID s so they can more readily provide

Component ID website, and that information is available to

4 Code 128 Barcode 16-character alpha-numeric code 2D Data Matrix Component ID The first two characters of the traceability identifier call out a unique manufacturer s code. A website was created by PPI under license from OTD (ComponentID.org) that now allows manufacturers to register their company's two character ID s so they can more readily provide traceability information that gas utilities can use in their implementation of DIMP. The manufacturer code is registered and maintained on the Component ID website, and that information is available to all. The following Figure 1, provides a screen shot of the Component ID website for reference. Figure 1: PPI Component ID website (downloaded June 18, 2014) 4 Copyright 2014 by PPCA

5 Manufacturer Implementation Status A White Paper, produced in 2014 by the American Gas Association and the Gas Technolgy Institute (GTI) entitled Distribution Asset Tracking and Traceability Industry Implementation Status Whitepaper and based on interview with select manufacturers, noted that numerous manufacturers have either started the barcode implementation process or are nearing completion. Fitting and component manufacturers appear to have an advantage in implementation using current technology. PE pipe manufacturers are in different stages, but are proving technologies that are adaptable to their unique manufacturing processes. Based on the AGA white paper and anecdotal discussions with numerous manufacturers many expect to have more fully developed marking across their product lines in Many companies have continued to develop various marking technologies across their product offering, but have been slowed by the huge discrepancies between operator implementation of DIMP and their ability to handle encoding technology. There has been much activity on the inclusion of ASTM F2897 encoding requirements into many of the plastic gas product standards. A list of standards referencing ASTM F2897 is shown in Table 2. Table 2: Gas product standards currently referencing ASTM F2897 ASTM D2513 Polyethylene (PE) Gas Pressure Pipe. Tubing, and Fittings ASTM F1973 Factory Assembled Anodeless Risers and Transition Fittings in Polyethylene (PE) and Polyamide 11 (PA11) and Polyamide 12 (PA12) Fuel Gas Distribution Systems ASTM F2509 Field-assembled Anodeless Riser Kits for Use on Outside Diameter Controlled Polyethylene Gas Distribution Pipe and Tubing ASTM F1924 Plastic Mechanical Fittings for Use on Outside Diameter Controlled Polyethylene Gas Distribution Pipe and Tubing ASTM F1948 Metallic Mechanical Fittings for Use on Outside Diameter Controlled Thermoplastic Gas Distribution Pipe and Tubing ASTM F2138 Excess Flow Valves for Natural Gas Service ASTM F2785 Polyamide 12 Gas Pressure Pipe, Tubing, and Fittings ASTM F2945 Polyamide 11 Gas Pressure Pipe, Tubing, and Fittings Gas Product Marking Technology Gas pipe and fittings are marked by the manufacturer at the time of production with a coding system specified in the ASTM product specifications. The markings can be imprinted directly onto the product, such as in a print string on pipe, or it may be included on an adhesive label or attached tag, as is common for fittings. Very small fittings may also include a loose tag in the packaging of the product. Current technology not well suited for barcode marking on continuously extruded pipe A summary of current printing technologies is provided in Table 3: 5 Copyright 2014 by PPCA

Table 3: Current Printing Technologies Printing Technology Application Issues Photo Indented print High abrasion resistance

PE Requires surface treatment UV Cured Extra process Adhesion can still be an issue Faster drying times Laser Newer

Difficult to apply on continuous pipe Direct line of sight not needed Labels More suitable for components than pipe Need to

require any specific technology or software.

6 Table 3: Current Printing Technologies Printing Technology Application Issues Photo Indented print High abrasion resistance Readability with scanners difficult Date change on continuous pipe an issue Ink Jet Most commercialized method Adherence on PE Requires surface treatment UV Cured Extra process Adhesion can still be an issue Faster drying times Laser Newer technology not yet proven on gas pipe May provide extended marking life No inks or chemicals used RFID Newer technology Difficult to apply on continuous pipe Direct line of sight not needed Labels More suitable for components than pipe Need to be protected from UV and external damage It should be noted that the implementation of tracking and traceability does not require any specific technology or software. The use of barcode scanning and supporting technologies can reduce the cost and time required for implementation, and may help reduce the chance of human error leading to greater system safety. 6 Copyright 2014 by PPCA

7 Considerations for Gas Product Producers We have reviewed the current technologies available to manufacturers to code their products. Gas pipe and component manufacturers are working to develop and implement existing technology and continue to develop new technologies for marking their products. There are a number of variables that complicate the implementation that need to be considered when developing new printing technologies that must be transferred to a range of product lines and production locations including: - Marking Technologies available - Expectations for current technology - Durability - Record retention - Development timeline for newer technology - Implementation across all products and production - Cost - Reader quality - Standard readers are designed for flat surfaces - Number of track and trace systems - Many operators with varying system requirements Marking permanency One of the most critical criteria to assess is the life expectation of the marking applied to the gas product. Pipe and component manufacturers are working to produce tracing & traceability marking that should be legible and readable at the time of installation. Current federal regulations require that the marking be readable at the time of installation. New regulations may alter these requirements. It is generally understood that tracking and traceability pipe markings should be able to withstand 2-3 years of normal exposure to outdoor storage before installation and normal installation handling practices, but that pipe markings may not survive some pull-in installation practices. Tracking and traceability label markings on fittings are not usually suitable for outdoor storage. To preserve label readability, fittings that are stored outside should be protected against exposure to the elements. The current state-of-the-art of barcode markings is that the markings can be applied to products and packaging, and the markings will initially be legible and readable (scanable). However, technology that will assure that these markings will survive extended exposure to the elements (weathering) and installation does not currently exist, especially in the case of installations that involve sliding the pipe and/or appurtenances through boreholes or casings or trench excavations. Product handling, assembly and installation and the placement of embedment materials around piping products can and does compromise product markings and labels affixed to products. Accordingly, the Marking and Traceability Program requires that at the time of product installation, pipeline system operators record not only the information from the ASTM F2897 product/product packaging marking, but also the product installation location. Development & Implementation Process Manufacturers must follow a lengthy implementation process for any new markings they desire to use on their products. A streamlined implementation process may include: 1. Select the printing technology 2. Select surface treatment method 3. Test and select inks 4. Test automatic data transfer 7 Copyright 2014 by PPCA

8 5. Evaluate the affect of any surface treatment 6. Establish min./max. surface treatment by line and size 7. Trials to prove readability 8. Complete for all gas pipe Use and Decoding of Traceability Markings The information contained in a T&T code is intended to provide basic information about a piping component that should help the user to know their system. The product manufacturer has the ability to decode the information upon request. Other sites for decoding may also be available. Including Apple and Android Apps available Generally the information contained in the traceability code should not need to be decoded in order to install or record installation of products. Much of the information in the T&T code is generally duplicated in standard product marking and may not be in the same order. Standard product markings (i.e.; indented print) are not typically scannable with a barcode reader. The barcode markings can be scanned with greater accuracy compared to manually entering product information from the product marking. Scanned T&T barcode information may be imported directly into system mapping files. Once a product is marked using standardized requirements, and the operator has recorded that information in their system along with location identification the information must be maintained to be useful. The system operator is responsible for storing data related to installation of products using the tracking and traceability code. Products complying with ASTM D2513 have a requirement of 50 years retention of production records. Other product standards may have different requirements and should be reviewed to determine how long records should be maintained. As noted the AGA whitepaper (2014), most operators have initiated formal or informal programs to develop a strategy for tracking and traceability including dialogue with Supply Chain Departments. Two operators have, or are in the process of, requiring vendors to comply with ASTM F2897. Three operators have started pilot projects to test technology to capture ASTM F2897 information in the field during installation and others 9 are evaluating technology options for field data capture. Some operators reported that very few components currently received are barcoded with the ASTM F2897 identifier. This clearly demonstrates the large amount of work that needs to be done to fully implement standardized marking and readability requirements across the gas distribution system. Conclusions and Recommendations Beyond DIMP it is unclear what specific direction federal regulations will take on the issue of tracking and traceability, but it is fairly certain that additional regulations are forthcoming. These new regulations will help drive the implementation of tracking and traceability systems further. Manufacturers will continue to develop marking capabilities as gas operators develop their ability to utilize the marking technology in their systems. Newer technologies in printing and barcode recognition such as: Laser or RFID may provide better ways of marking, reading, and recording data. It is expected that Operator tracking & traceability systems will become more sophisticated as they transition from manual operations to electronic. While there is no current technology that will assure that ASTM F2897 markings on installed products will be legible in whole or in part after installation, future developments should improve marking capabilities, readability, and longevity.. Plastic gas distribution pipe and component manufacturers support enhanced system knowledge through standardized marking. Current technology can meet the requirements of ASTM F2897, various product standards, and help Operators know their system. PPI members will continue to develop new technologies in printing and barcode recognition. PPI CID will maintain ongoing manufacturer code 8 Copyright 2014 by PPCA

9 information. The product manufacturer should be consulted for details for specific product marking information. ACKNOWLEDGMENTS I would like to acknowledge the support of PPI members who have invested their time and effort into developing a responsible tracking and traceability system that can be widely implemented in gas distributions systems. REFERENCES Contained within the body of the document 9 Copyright 2014 by PPCA

Tracking & Traceability Industry Implementation Status. AGA Tracking and Traceability Workshop - Alicia Farag

Tracking & Traceability Industry Implementation Status AGA Tracking and Traceability Workshop - Alicia Farag 1 Overview Tracking and Traceability Vision ASTM F2897 Plastic Pipe NPRM Purchasing Specification