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Typically, this is handled through checklists items during the formal MOC process: the myriad of MOCs are all passed through the EHS department whose job it is to review the change, identify if the change impacts one of the applicable compliance programs. And if it does? The EHS department coordinates field work to update the applicable inspection or maintenance compliance program: such as adding or removing the equipment from an inspection database.
In an ideal world, the MOC process doesn’t fail: all applicable compliance programs are updated. However, the reality of a complex and ever changing plant means things can slip through the cracks. The result is that compliance inventories fall out-of-date over time. For Leak Detection and Repair (LDAR), this is why plants typically do costly retags (re-validations of the inventory) every 5-10 years; or why overlooked equipment is a consistent EPA audit finding
Regulators know that the MOC process breaks down. Every CD ELP (“Consent Decree Enhanced LDAR Program”) has contained requirements to ensure “each piece of Equipment added or removed [from the plant] is evaluated to determine if it is or was subject to [regulatory] requirements, and [if so] the Equipment is [updated in the compliance program].” And recent regulatory CDs have contained requirements to validate the work (See Appendix B, Paragraph 26, Page 153, BP Whiting 2012 Consent Decree).
The problem is: how do you validate the MOC process? And how are you validating the process in a thorough and cost-effective manner? How are you ensuring added and removed equipment is captured through the MOC process?
Typically the final validation on the process is time-consuming field review: a “hunt-and-peck” process of attempting to identify the “needle-in-a-haystack” of a added or (harder yet) removed piece of equipment. This “hunt-and-peck” process is usually only guided by the MOC documents which are flagged properly through the MOC process and hit a particular compliance coordinator's desk. If something goes wrong during the MOC process, it’s missed.
Instead of depending on solely on manual checklists and time-consuming “hunt and peck” field reviews, what if you could leverage a modern approach to validating the MOC process? We know that the CAD department updates the “As-Built” set of P&IDs through the MOC process, and these “As-Built” P&IDs are field walked and validated through the Process Safety Management (PSM) Process Hazard Analysis (PHA) process.
What if when these P&IDs were updated, it was possible to generate a detailed report of all equipment which was added, removed, or modified? And instead of wasteful “hunt-and-peck” fieldwork, compliance technicians were given a laser-focused list of equipment modifications to address.
This has been the mission of Ei for years: to find ways to leverage simple tools and modern approaches to optimize how plants operate and maintain their compliance programs. Our team has first-hand experience with ‘the old way,’ and has always believed there is a “better way.” After years of innovation, we’re finally joining two of our core features to develop our crowning achievement: a “better way” to manage and validate compliance programs and inventories.
First, our data-driven approach to highlighting P&IDs for compliance allows us to do something incredibly powerful and modern: query and export lists of equipment subject to various regulatory requirements. We’ve been using these data lists for years to QA/QC and validate the highlighted P&IDs we deliver to our customers.
Second, our newly optimized P&ID update approach allows us to update plant’s highlighted P&IDs incredibly inexpensively, without the requirement to coordinate heavily with overworked CAD departments.
Combining these two results in us being able to provide our customers with a detailed inventory of equipment that is modified every time we update a set of highlighted P&IDs. This change report can be used as a field-validation worklist for our customers MOC technicians. This may seem simple (and it is), but this gives our customers a targeted list to perform a final validation on their MOC process.
Ei has developed a cost effective approach to validate compliance, closing the loop on the MOC process allowing customers to finally achieve sustainable compliance. How does it work?