About Systemic Compliance
- We Built Systemic Compliance Because the Industry Deserved Better
Pipeline compliance has a systemic problem — and it isn’t regulations.
The problem is that Operators are managing contractor compliance through platforms built by vendors who don’t understand their specific program. Contractors are navigating systems that were never designed with them in mind. And when something goes wrong — when a qualification lapses, a procedure changes, or an auditor asks a hard question — everyone finds out too late that the gaps were there all along.
We built Systemic Compliance to change that.
Who We Are
Systemic Compliance, LLC was founded in early 2025 by Kevin Graham and select members of the original core team behind Veriforce. After successfully building and exiting Veriforce in 2009, Kevin watched the industry change under private equity ownership. Too often, the focus shifted away from Operators, contractors, and practical solutions. Frustrated by this shift, Kevin and his original team decided it was time to come back together and do things the right way.
With more than 30 years dedicated to HSE and regulatory compliance in the oil and gas industry — primarily pipelines and offshore E&P — Kevin has deep, hands-on expertise. He founded Veriforce in 1998 to support DOT/PHMSA Operator Qualification (OQ) requirements and represented pipeline Operators in dozens of regulatory audits. His career also includes leading compliance organizations and overseeing SEMS audits in the Gulf of America.
Our Mission is straightforward and twofold:
- Help oil and gas pipeline Operators directly with regulatory compliance and the development and implementation of robust Pipeline Safety Management Systems (PSMS).
- Help their contractors successfully meet the requirements of the Operators they support.
We are changing how our customers view regulatory compliance. Rather than treating it as a burdensome checkbox exercise, we provide intelligent software, expert consulting, and practical support that build efficiency and cost savings directly into your operations. Regulatory compliance then becomes a natural byproduct of smarter systems — not the driving force.
With all of this experience and insight, our eyes are firmly looking forward to Pipeline Safety Management Systems (PSMS). We are committed to helping Operators implement a comprehensive, proactive PSMS framework (aligned with API RP 1173) that go beyond minimum compliance — creating a true culture of safety, operational excellence, and continuous improvement across the pipeline industry.
At Systemic Compliance, we believe compliance should be systemic. By prioritizing risk minimization, operator-specific needs, practical solutions, and true integration, we deliver lasting value for both Operators and their contractor partners.
- Guiding Principles
- We will provide smart solutions to real problems
- We will look at issues and challenges differently than anyone has before
- We will craft solutions that improve the performance and health of the client's business
- We will build systems that complement how a company operates — compliance will be a result, not the primary aim
- We will always choose to do the right thing
- The Systemic Compliance Consulting Team: Unrivaled Industry Expertise
Our consulting team isn’t built from generalists — it’s built from the people who wrote the standards, enforced the regulations, and built the programs your industry relies on today. Former PHMSA inspectors, accident investigators, pipeline operators, and regulatory committee members with a combined 175+ years of hands-on experience in pipeline safety, OQ, PSMS, and DOT compliance. When you work with Systemic Compliance, you’re working with people who have been in the room when it mattered.
Our Team
Kevin Graham
Founder, Systemic Compliance
30+ Years in Pipeline Compliance, OQ & Management Systems
- Veriforce Founder & Original Creator
- Smith System Pinion VP & GM, OQSG
- Industrial Solutions Group VP of Compliance
- ANSI/ASME B31Q Technical Committee Member
- API RP 1173 & API RP 1161 Working Groups
- API Approved SMS Assessor
Michael (Mike) Comstock
SME/Advisor
40+ Years in Natural Gas Pipeline Safety & Utilities
- EverLine, LLC Utilities Market Director
- C&M Regulatory Pipeline Consultants Principal
- City of Mesa Energy Resources & Solid Waste Leadership
- ANSI/ASME B31Q Technical Committee Member
- APGA Chairman
- API Approved PSMS Assessor
Warren Miller
SME/Advisor
50+ Years in Pipeline Safety & Regulatory Compliance
- PHMSA/DOT Inspector, Accident Investigator, Operations Supervisor
- Co-developed National OQ Inspection Protocols
- ANSI/ASME B31Q Technical Committee Member
- OQ Integrity Coalition Founding Member
- API Approved PSMS Assessor
John Chin
SME/Advisor
46+ Years in Design, Construction, Corrosion, OQ & Integrity Management
- TransCanada/TC Energy Sr. Regulatory Compliance Specialist
- El Paso Pipeline Group Principal Compliance Engineer, OQ Committee Chair
- ANSI/ASME B31.8 Code Committee Member
- ANSI/ASME B31Q Technical Committee Member
- API Approved PSMS Assessor
Brad Heck
SME/Advisor
40+ Years in Pipeline Safety, OQ, PSMS & D&A Programs
- Miller Pipeline LLC Director of Corporate Compliance
- OQ Integrity Process (OQIP) Coalition Co-Founder/Chair
- ANSI/ASME B31Q Technical Committee Member
- Midwest Energy Association Hall of Fame Inductee
- API Approved PSMS Assessor
Our Team
Kevin Graham
Founder
30+ years in pipeline compliance, OQ, and management systems
Career Highlights
- Founder – Systemic Compliance, LLC (Nov 2024 – present)
- Founder & original creator – Veriforce, LLC (1998–2009)
- VP & GM, OQSG / Smith System Pinion (2018–2024)
- VP of Compliance, Industrial Solutions Group (2015–2018)
- Director of Compliance, M&H Energy Services (2011–2014)
Industry Leadership
- Member: B31Q Committee
- Member: API RP 1173 Working Group
- Member: API RP 1161 Working Group
Michael (Mike) Comstock
Consultant
40+ years in natural gas pipeline safety & utilities
Career Highlights
- Independent Consultant – 49 CFR 190-199 compliance (May 2025 – present)
- EverLine, LLC – Utilities Market Director (2022–2025)
- C&M Regulatory Pipeline Consultants – Principal (2018–2022)
- Veriforce, LLC (2015–2018)
- City of Mesa – Energy Resources & Solid Waste leadership (1999–2015)
Industry Leadership
- ASME B31Q Standards Committee member
- Federal Technical Pipeline Safety Standards Committee (2005–2011)
- 2009 Chairman, American Public Gas Association
- APGA Distinguished Service & Personal Achievement Awards recipient
Warren Miller
Consultant
30+ years in pipeline safety & regulatory compliance
Career Highlights
- 23 years at PHMSA/DOT (1991–2014) — Inspector, Accident Investigator, Operations Supervisor
- Co-developed national OQ inspection protocols
- Independent Consultant (Sep 2024 – present)
- Industrial Training Services – Regulatory Compliance Specialist (2021–2024)
- Warren Miller Enterprises, LLC – Owner/Consultant (2016–2021)
Industry Leadership
- Charter Member, ASME B31Q Standards Committee (2003–2024)
- Founding Member, OQ Integrity Coalition
John Chin
Consultant
46+ years in pipeline design, construction, corrosion, OQ, and integrity management
Career Highlights
- TransCanada/TC Energy – Sr. Regulatory Compliance Specialist (2007–2021)
- El Paso Pipeline Group – Principal Compliance Engineer, OQ Committee Chair (2001–2007)
- Coastal Corporation – Supervisor-Codes/Standards/Regulations (1985–2001)
- Michigan Wisconsin/ANR – Manager of Codes & Standards (1975–1985)
Industry Leadership
- ANSI/ASME B31.8 Code Committee (13 years task group chair)
- ANSI/AGA Z380 Gas Piping Technology Committee (13 years task group chair)
- ANSI/ASME B31Q Technical Committee
Brad Heck
Consultant
40+ years in pipeline safety, DOT compliance, OQ, PSMS, and substance abuse programs
Career Highlights
- Principal, American Compliance Enterprises (2011–present)
- Director of Corporate Compliance – Miller Pipeline LLC (1994–2024)
Industry Leadership
- Co-founder/Chair – OQ Integrity Process (OQIP) Coalition
- Vice President of OQIP 501(c)(3)
- Voting member – ASME B31Q Technical Committee
- 014 Midwest Energy Association Hall of Fame inductee
Ready to Work With a Team That Actually Knows This Industry?
If you’re ready to build a compliance program that actually works — for your operations, your contractors, and your next PHMSA audit — we’d like to talk.