The Oil & Gas industry faces a unique environmental management challenge, one that affects the daily success day to day business: having to manage emissions from hundreds (to thousands) of sources that are spread out great distances apart. And frequently in areas subject to different regulations.
A small EH&S team, working from a central location, may be responsible for monitoring emissions and environmental performance for a tank battery, flare, pipeline, or Vapor Recovery Unit (VRU) several hours away. Sometimes several states away.
No matter how skilled the EH&S team, this operating strategy is bound to create problems. And those problems can land you in hot water with regulators because you’re going to experience the following common and costly problems:
- Barriers to how quickly and effectively you respond to issues.
- EH&S data isn’t collected efficiently or in a timely manner.
- Writing compliance reports takes more time and effort than it should.
- Work harder for fewer results.
If you are an Oil & Gas executive or an EH&S Manager working for an Oil & Gas business who has noticed one or more of these issues, chances are it’s because you don’t have the right system in place to deal with the natural and unavoidable challenges of your industry.
And here’s how you can change that.
Shorten Response Times With Automated Data Collection
The most common complaint heard from Oil & Gas environmental professionals is that they simply cannot respond quickly enough to events at their disparate facilities. An environmental manager can often be left in the dark about an emissions leak or other reportable event until weeks after the fact once they finally get the facility’s data transferred to them.
By then the opportunity to respond promptly and effectively has been lost.
When something goes wrong at a tank battery in some other state, there is a lot at stake. Not only is your reputation and compliance record in jeopardy, the resulting emissions are literally your product and your money going up in smoke. Time is money in these cases, and no one wants to lose weeks’ worth of money simply because they couldn’t respond in time or didn’t have the information needed to respond appropriately.
Compounding the problem, the EPA usually issues a violation fine for failing to report the event within 24 hours – even though you couldn’t have possibly had the information in hand in that turnaround time (without a proper EMS system in place first). Because of this catch 22 sometimes even a small reportable or preventable event could end up costing a lot more than you expect.
In the aftermath of these types of occurrences EH&S professionals are still fighting an uphill battle. Since they didn’t have up-to-the minute data and are responding to the aftermath of an emissions event, environmental specialists in the Oil & Gas industry are usually forced to dig through old maintenance logs to discover the root cause of issues, which is not the most efficient use of their time nor the best way to get the data needed.
Instead, root cause analyses are better off using daily production records and continuously monitored parametrical readings (collected every second or minute by a CPMS device). In the absence of these resources, as is often the case in the busy Oil & Gas industry, environmental managers have to make do with what’s at hand.
The solution is to implement a data management system that automates data collection from control devices using Continuous Monitoring devices. That way, even a remotely located EH&HS Manager can have near-instantaneous (literally minute by minute) access to a distant facility’s performance data and respond as promptly as possible.
Having that style of automated data collection typically requires having a dedicated database with a secure online connection to monitored sites so that emissions and parametric data can be transferred electronically via online portal. Although setting this up may first sound complicated, off-the-shelf solutions already exist for automatically capturing and uploading this type of data stream.
Alleviate Compliance Reporting Pains With Standardized Data Collection
Even when there aren’t leaks or emergencies to take care of, not having access to your data the moment you need it puts a strain on your routine tasks as well. Completing a compliance report using data for another state means extra planning ahead.
If you were to ask a group of Oil & Gas EH&S professionals what they want most when facing a looming compliance deadline the typical response is to be able to see all their environmental and emissions data at a glance with the click of a button.
Instead, without a system in place to let them do that, those busy managers end up digging through piles of spreadsheets (all using a different tracking methodology) from sites across the country. It also means that those reporters have to be on the top of their game in knowing when reports are due for each different state, as they will need extra time to collect and decrypt all that data from far away facilities.
To streamline your reporting, implement a system that standardizes data collection from facilities – or at least creates a secure, centralized database for every facility to enter data into – Oil & Gas environmental managers and their teams will shave time off of how data is collected and shared.
The major obstacle in Oil & Gas facility reporting is a lack of clear data: it’s not always evident where data has come from, when it was entered, who recorded it, or if the data relates to regular operations or an MSS or AOS event. Once you have a central database and a clear set of guidelines for collecting data, more than half of the time you previously spent preparing for reports can be eliminated since you’ll have cut out the bulk of the most time-consuming work.
In cases when data gaps exist because there is no employee on site responsible or able to collect emissions and productivity data, it’s worth installing Continuous Emissions Monitoring (CEM) and Continuous Parametric Monitoring (CPM) devices. Though these CEM/CPM systems can be a large initial investment, for an industry like Oil & Gas they end up being smart decisions since those violation fines add up quickly.
Stay Ahead Of Deadlines And Industry Regulation Changes
Keeping on top of permitting and regulatory management is also an issue when multiple states are involved. In most other industries an EH&S manager only needs to be an expert on the water, waste, and air regulations for their one main manufacturing facility. However, in the case of Oil & Gas, environmental managers may need to know the ins and outs of dozens of individual state regulations.
Oil & Gas EH&S managers do an amazing job of knowing the requirements of the states they operate in and keeping all the subtle differences straight in their minds. While they should be applauded for this skill, there is a simpler way of managing all those compliance reports.
Many industries with similarly complex regulatory situations have found it beneficial to invest in a regulatory compliance management system that automates regulatory updates, deadline reminders, and accountability. These types of systems tap into central regulatory databases that are monitored and updated constantly so that newly added substances or changed reporting thresholds are never overlooked. It also sends out automated reminders of upcoming external and internal deadlines so that you know when you need to start working on your reports.
Executives in the Oil & Gas industry also find implementing this type of system, usually web-based management software, extremely helpful. It can provide them with a bird’s-eye view of their operations, including which deadlines are approaching, which have been met, where their teams have fallen behind, and who is in charge of which tasks. When you’ve got a team of EH&S Managers covering a diverse portfolio of assignments, it can be easy to lose track of your overall progress. Having compliance task management software can be the perfect bridge between the important small details and the big picture.
Improving the real time flow of data in your organization
Having complete control and access of your own environmental data is the lifeblood of a healthy and productive EH&S department. When time and distance create obstructions to that natural flow of data up from your sites to your central HQ, your business is at risk for regulatory violations, inefficient responsive actions, and your general environmental management becomes an uphill climb.
The natural counterpoint to distance-related delays in data management is to automate and centralize as much of your data processing as possible. Centralizing your environmental record databases with a secure online portal puts you back in control of your data acquisition and lets your data leap over those great distances between sites.
And when there is no EH&S specialist on site to collect data for those distant sites, automating your data collection using EH&S technology will still keep you in the driver’s seat for those facilities.
In addition to generally making EH&S management more effective, automation and centralization mean that you are more able to be proactive and successful in how you deal with events in which your attention is required immediately. Getting an automated warning the minute something goes wrong and getting an email with all the relevant data about the emission release means that your response will be faster and more likely to bypass serious consequences.
Multiple Challenges, a Single Solution
All of the challenges mentioned here are natural results of how the Oil & Gas industry operates: having multiple sites located in multiple states, higher than average movement across EH&S departments, stricter regulations, and more complicated operating scenarios can all amount to more complex management needs.
However, although your business faces multiple challenges, you don’t necessarily need multiple solutions. Instead, seek out a singular systemic solution that addresses the key issues of time and distance. Having an automated system implemented and standardized across your sites can stand in for having a full staff of EH&S Managers at every location, making it feasible for a single EH&S team to manage the entire business from afar.
Ask an ERA Expert:
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Photo credit: Sherman Geronimo-Tan
About the Author: Alex Chamberlain is a writer and blogger who regularly contributes to ERA Environmental Management Solutions' blog. You can find Alex on Google+, LinkedIn & ERA's Environmental Compliance blog