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 AEC+Compliance Paradigms
Shane Kling
Shane Kling
Shane E. Kling is a Chemical Engineer and Founder of Ei Holdings, a conglomeration of CAD + compliance companies serving the oil and gas, chemical and other industries. In his work with Environmental intellect (Ei), EiCAD and other firms, he has supported more than 150 owner-operators with CAD + … More »

Why Industry-Standard CAD Platforms DO NOT Meet Owner-Operators’ Compliance Needs

 
May 27th, 2014 by Shane Kling

I am wrapping up one of the more ambitious business trips in my career. For the last 9 years, I have consulted owner-operators in the oil and gas, chemicals, and petrochemicals industries on compliance with U.S. Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) regulations. To enlighten other business travelers, I have ventured more than 5,500 miles and met with 19 owner-operators in Texas, Louisiana, Michigan, Illinois, and Utah – and all within 9 business days. But this is not a “traveler’s blog,” so I will expand on the topic at hand, which is why industry-standard CAD platforms, do not, cannot, and will not ever meet the compliance needs of owner-operators.

My headlining claim –Why Industry-Standard CAD Platforms DO NOT Meet Owner-Operators’ Compliance Needs- is absolutely controversial. There are millions of CAD users around the world that either use AutoCAD™, Microstation™ or a slew of other CAD platforms that I collectively refer to as “industry-standard” CAD applications. The nuances between various CAD platforms may be as dynamic as the differences between operating systems, such as Linux, Windows, and Apple OS. But industry CAD platforms all have one common bond: none is data-driven. That is, very few owner-operators employ a CAD system that enables the user to extract information and data. In fact, CAD applications are one of the few, remaining data systems at operating plants that have not been upgraded into a data-driven format.

Our company, Environmental intellect (Ei), is embarking upon a long and arduous journey to educate owner-operators; particularly those in the oil and gas, petrochemical, and chemical industries on the limitations of industry-standard CAD platforms. I assert that a facility’s schematics – more specifically their piping and instrumentation diagrams (P&IDs) – are a facility’s “foundation for compliance.” I have noticed an unnerving trend in the industry that is leading to increased costs and compliance risks: when an owner-operators P&IDs are inaccurate and/or out-of-date, then they manage regulatory programs with elevated compliance risk.

Many owner-operators invest millions of dollars annually into maintaining “accurate” P&IDs because industry-standard CAD platforms can only be remediated with additional labor (i.e., costs). This is simply not a sustainable solution for a facility’s needs to access, manage, and update data associated with schematics. In our world of data-driven solutions, there is a critical need for CAD programs to be data-driven to aid in managing the increasing number of data and requirements associated with plant operations. This change is inevitable, and it must happen on a fundamental level – within the P&ID!

There are numerous OSHA and EPA compliance programs that are driving owner-operators’ needs to upgrade industry-standard CAD applications because several compliance programs rely on P&IDs to form a basis for applicability and to certify and/or report compliance. The following list provides just a few of the regulations that rely on P&IDs to build and maintain the regulatory compliance program:

  1. Process Safety Management (PSM);
  2. Leak Detection and Repair (LDAR);
  3. Benzene Waste Operations NESHAP (BWON);
  4. Greenhouse Gas (GHG);
  5. Annual Emissions Inventory Reporting (SARA 312); and
  6. Toxic Release Inventory (SARA 313).

For example, the PSM regulation, which was promulgated in 1992, details 14 elements that owner-operators with applicable processes must adhere to. One of these 14 elements is a P&ID review and update as part of a process hazard analysis (PHA) revalidation – this must be completed at least every 5 years. One needs only to understand that two of the most prevalent CAD platforms, AutoCAD™ and Microstation™, were released in 1982 and 1987, respectively, to conclude that neither software was designed to support the compliance requirements of the PSM regulation. Likewise, the LDAR and BWON compliance programs require a P&ID review to build the basis for equipment that is inventoried, monitored, controlled, and reported upon to EPA to demonstrate compliance.

Facility schematics, such as P&IDs, are critical documents for both environmental and safety compliance.  Yet, the CAD programs used to draft, manage, and update facility schematics are generally no more “intelligent” than a coloring book and crayons – that is, the P&ID drafted in today’s industry-standard CAD programs are generally a “static” representation of the process without any ability to extract data and information. Compliance risks and operating costs will continue to increase so long as industry-standard CAD platforms do not shift from an “unintelligent” to “intelligent” database-enabled format.

I have stated the problem in painstaking detail – industry-standard CAD platforms are not inherently data-driven. So, what do I believe the answer is? A paradigm shift from current industry-standard CAD platforms to data-driven CAD platforms.

There are “smart” CAD products on the market, such as SmartPlant® P&ID and AutoCAD P&ID™, and there are also plugins that are used to incorporate meta-data into industry CAD platforms (e.g., CADWorx™). But how widespread are the use of these “smart” CAD platforms? Some might assert that EPCs have generally established SmartPlant® as the industry-standard for design and construction projects, but what happens to the data and intelligence in CAD files when these projects are finished and turned over to owner-operators? The data (or “intelligence”) is typically stripped from the “smart” P&ID project, and what was once a “smart” P&ID is turned into a “dumb” P&ID in the format (.dwg or .dgn) specified by the owner-operator (read: awareness and communication between EPCs and owner-operators must improve, and I will address this opportunity to improve the plant lifecycle in a future blog).

It is becoming more critical that we improve awareness that industry-standard CAD platforms were neither designed nor are capable of fulfilling owner-operators’ compliance needs. Furthermore, it is of paramount importance that the vendors, consultants, and other support arms of these industries bring forth data-driven solutions that fulfill the customer’s needs while also reducing long-term costs. I believe that “smart P&ID” platforms are a solution to this issue, and my visits to owner-operators are proving to be both an epiphany and the beginning of process to explore how enhanced CAD technology can improve plant and compliance management systems.

To summarize, industry-standard CAD platforms were not designed to meet the needs of owner-operators nor can they provide a sustainable solution for these needs because these platforms involve:

  1. Analog Data – There is minimal access to extract critical compliance, operations, design, and other data that is either implied or expressly written into CAD files.
  2. Inability to Integrate and Automate – Industry-standard CAD platforms cannot be integrated with related data systems to automate compliance and operational tasks and achieve reduced operating costs.
  3. Increasing Costs – There is no mechanism to reduce costs of maintaining P&IDs in industry CAD applications, especially in today’s regulatory enforcement climate and following plant expansions (more P&IDs –> more labor –> more costs).
  4. Minimal Return on Investment – Owner-operators will continue to spend significant capital (often exceeding $1MM) to maintain and update P&IDs with little opportunity to get any future cost savings or return on this recurring, annual investment.
  5. Antiquated Technology – The very manual and labor-intensive processes associated with industry-standard CAD platforms does not leverage best available technologies.

In closing, not one owner-operator we have met with has yet to tell us that they do not have a need for an enhanced, data-driven CAD solution (in fact, many are engaging with us to conduct pilot studies). Furthermore, we are on the cusp of a “paradigm shift” that will bring front-and-center the need and importance of leveraging data that is currently locked within industry-standard CAD platforms. In this writer’s opinion, a data-driven CAD solution is the only way that owner-operators will ever achieve sustainable plant and compliance management systems. Other AEC service and product providers will soon find themselves with a critical decision to make to sustain competitive advantage in the AEC industries: embrace data-driven CAD platforms or continue utilizing industry-standard CAD platforms that do not meet owner-operators’ needs?

Questions? Comments? Contentions? Feel free to email me at shane@env-int.com to extend this discussion on AEC + Compliance Paradigms.

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