In last week’s blog, we touched on “quality”: approaches we use for implementing “tech fixes” and work-practices to address common issues, as well as some unique reviews we can do with iP&IDs we use on these project. From that post, we received a lot of feedback from followers asking for more info on some of the “QA/QC” they can use on their projects.
QA, QC, or QA/QC?
QA/QC, QA/QC, QA/QC… one of the biggest buzzwords in the LDAR industry. When people say QA/QC, it usually means, in layman's terms: “make sure we don’t get in trouble when the EPA shows up.”
But really, QA/QC is an acronym for Quality Assurance / Quality Control. What does that mean in relation to the LDAR programs we all have a hand in? Let's look at the definitions posted on the American Society for Quality (aqs.org) website:
“Quality Assurance: The act of giving confidence, the state of being certain or the act of making certain.”
“Quality Control: An evaluation to indicate needed corrective responses; the act of guiding a process in which variability is attributable to a constant system of chance causes.”
Let’s spin these actual definitions into terms that make sense from a LDAR perspective - specifically during an LDAR retag:
LDAR Quality Assurance: Checking the inventory work, usually after it’s done, to make sure it’s “right”. Or: “the final check of the data.”
LDAR Quality Control: What you do doing the project to minimize “bad” data from being collected. Or: “the controls you put in place when running the project.”
QA/QC is an industry buzzword for a reason: it’s how you assure compliance. But all too often, we find that folks aren’t focusing equally on both QA and QC. As former LDAR auditors, we observed that most contractors focus solely that “end-of-project” check they do to “assure” compliance before they hand-over the LDAR data to the client.
Question: Is a 10% spot-check of retagged components “good enough” to ensure compliance in this regulatory environment? Absolutely not.
This is why it is so important to focus just-as-heavily on the *quality controls* (QC) you build into the project as you do on the end-of-project QA - to prevent issues/errors from having to be fixed during QA. And that’s just what our LDAR Projects team is focusing on this week.
The QC We Build into Our Software and Projects
The last blog post we touched briefly on some of the QC we build into our projects, but it’s worthwhile to share a few more details about the software-based QC we build into our FieldTech Toolbox™ software. Below is just a partial list of the QC we’re implementing for our retag project at a Louisiana Refinery:
Regulation-Specific Controls: Regulatory applicability impacts which components do/don’t get inventoried during a project. For this retag, the particular process unit is subject to Louisiana MACT, which requires all connectors 1” and greater to be documented. So, we built a QC feature for “component confirmation” - if a technician documents a valve that is 1” or greater, but does not document any children connectors with it, they are prompted to verify
Tag Number Validation: It’s easy to document tag numbers with extra zeroes or decimals that are out of place (e.g., Tag 1000432 sure starts to look like a 100432 after a hard-day's work!). Therefore, we build in a tag range QC check to ensure they don’t forget to type all of the digits.
Title V Compliance: Make Sure to Document the Old Tag: We make sure our LDAR Professionals do everything they can to document the Old Tag on any added component (even if the tag is cut / missing). If they forget to do this, FieldTech Toolbox™ has a QC check to remind them to document the Old Tag.
Title V Compliance: Only Valid Old Tags Are Documented: Since our FieldTech Toolbox enabled technicians have access to all of the components in the client’s database, they get a warning if they type in an old tag number that isn’t in the database.
Ghost Tags: What if the documented Old Tag is hanging in the field; it’s in service; but it’s not active in the database? It’s a “Ghost Tag!” And yep, we got a QC check for that, too. Our professionals select a checkbox to denote ‘Ghost Tags’, and the data is easily compiled into a report of those spooky tags to our clients during the project and as attachments within our closeout memorandum!
Title V Compliance: No Duplicate Old or New Tags: We also build in a QC check ensure our LDAR professionals don’t “double-dip” and document an Old Tag twice.
Same QC check duplicate New Tags!
Require Detailed, Unique Location Descriptions: With FieldTech Toolbox™, we can control whether or not LDAR Professionals document duplicate location descriptions. Some sites allow duplicate location descriptions; others do not. This QC check helps remind our team to always document detailed location descriptions in alignment with our client’s SOP - no matter how weird the format or what language it is (Simplified Chinese, anyone?).
Controlling the Component Types Used (both for Parents and Children): We pre-program our inventory software to only include component types and subtypes that are approved to be used during the project. If one of our LDAR professionals chooses to override one of these values, they’re asked to confirm. Furthermore, FieldTech Toolbox™ lets us define what component Types / Subtypes are allowed for parents, and which ones are allowed for Children (preventing Gate Valves being sloppily documented as children to another valve, for instance).
Eliminating Orphan Tags: From the ground-up, we build FieldTech Toolbox™ to eliminate the chance of creating orphan tags (that is, connectors where the parent valve wasn’t documented). For example, Tag Number 10000.01 wouldn’t normally exist without Tag Number 10000.
Location Builder: Every little efficiency gain counts when you start to get as fast as FieldTech Toolbox™. So, we utilize our Location Builder to allow each LDAR professional quickly generate compliant location descriptions to conform to site SOPs.
Why Quality Control Matters
Compliance! Compliance! Compliance! A common industry practice is to have a senior LDAR professional do final spot-checks on 10-20% of the total newly-added LDAR inventory, which includes field review with a stack of P&IDs and a printed Master Equipment List (MEL). Although this is a great practice (and one that we don’t short on)… this still leaves 80-90% of the project’s compliance data points un-checked and un-validated.
Without ample Quality Controls in place during the project, the number of potential non-compliance issues that could be present in that 80-90% are ASTRONOMICAL!
Prevent Rework: Our LDAR Projects team executes our projects on a Time and Materials, fixed-cost basis. What does that mean? Any re-work hurts our “bottom line,” so. we’re strongly incentivized to eliminate costly re-work, and the best way to do that is to build layers of Quality Control throughout the project.
In closing, QA/QC is one of the most frequently used buzzwords in our industry, and rightfully so. In the current climate of EPA-issued Consent Decree Stipulated Penalties, and increased scrutiny on LDAR from the Federal and Local air agencies, compliance can only be achieved through targeted focus on both the QA and QC side of QA/QC. At Ei, we’re continuing to enhance our team and products to bring you the best of both.
Have an idea for a quality control, or a nagging pain point from a recent project? Reach out to me at firstname.lastname@example.org, I’d be happy to explore how we can build you a quality control for your next project.
For those of you wondering about the GIF image... it's from one of the author's favorite inspirational YouTube videos used to "pump him up" before any technical presentation he gives. Check out the Rockwell Retro Encabulator video if you want a 2-minute laugh!