IoT-based “Regulation 3.0” Might Have Avoided Merrimack Valley Tragedies

Pardon me: this is a very personal post.

For about an hour Thursday night we didn’t know whether my son’s home in Lawrence was one of those blown up by the gasline explosions (fortunately, he and his dear family were never at risk — they’re living in Bolivia for two years — but the house was right at Ground Zero). Fortunately, it is intact.

However, the scare took me back to an op-ed I wrote eight years ago in Federal Computer Week after the BP catastrophe in the Gulf, when I was working in disaster communications. I proposed what in fact was an IoT-based way to avoid similar disasters in the future: what I called “Regulation 3.0,” which would be a win-win solution for critical infrastructure companies (85% of the critical infrastructure in the US is in private hands) and the public interest by installing IoT-monitoring sensors and M2M control devices that would act automatically on that sensor data, rather than requiring human intervention:

  • in daily operations, it would let the companies dramatically increase their efficiency by giving real-time data on where the contents were and the condition of pipelines, wires, etc. so the operations could be optimized.
  • in a disaster, as we found out in Lawrence and Andover, where Columbia Gas evidently blew it on response management, government agencies (and, conceivably, even the general public, might have real-time data, to speed the response (that’s because of one of my IoT Essential Truths, “share data, don’t hoard it”).

We could never have that real-time data sharing in the past, so we were totally dependent on the responsible companies for data, which even they probably didn’t have because of the inability to monitor flow, etc.

Today, by contrast, we need to get beyond the old prescriptive regulations, which told companies what equipment to install (holding back progress when new, more efficient controls were created, and switch to performance-based regulation where the companies would instead be held to standards (i.e., in the not-too-distant future, when the IoT will be commonplace, collecting and sharing real-time data on their facilities), so they’d be free to adopt even better technology in the future.

However, Regulation 3.0 should become the norm, because it would be better all around:

  • helping the companies’ improve their daily operations.
  • cutting the cost of compliance (because data could be crunched and reported instantly, without requiring humans compiling and submitting it).
  • reducing the chance of incidents ever happening (When I wrote the op-ed I’d never heard of IoT-based “predictive maintenance,” which lets companies spot maintenance issues at the earliest point, so they can do repairs quickly and cheaper than if having to respond once they’re full-blown problems.).

I had a chance to discuss the concept yesterday with Rep. Joe Kennedy, who showed a real knowledge of the IoT and seemed open to the incident.

Eight years after I first broached the concept, PTC reports that the pipeline industry is now impementing IoT-based operations, with benefits including:

  • Situational awareness..
  • Situational intelligence..
  • and Predictive analytics.

Clearly, this is in the economic interests of the companies that control the infrastructure, and of the public interest.  The Time has come for IoT-based “Regulation 3.0.”

 

Failure to inspect oil rigs another argument for “real-time regulation”

The news that the Bureau of Land Management has failed to inspect thousands of fracking and other oil wells considered at high risk for contaminating water is Exhibit A for my argument we need Intnet of Things-based “real-time regulation” for a variety of risky regulated businesses.

According to a new GAO report obtained by AP:

“Investigators said weak control by the Interior Department’s Bureau of Land Management resulted from policies based on outdated science and from incomplete monitoring data….

“The audit also said the BLM did not coordinate effectively with state regulators in New Mexico, North Dakota, Oklahoma and Utah.”

Let’s face it: a regulatory scheme based on after-the-fact self-reporting by the companies themselves backed up by infrequent site visits by an inadequate number of inspectors will never adequately protect the public and the environment.  In this case, the GAO said that “…. the BLM had failed to conduct inspections on more than 2,100 of the 3,702 wells that it had specified as ‘high priority’ and drilled from 2009 through 2012. The agency considers a well ‘high priority’ based on a greater need to protect against possible water contamination and other environmental safety issues.”

By contrast, requiring that oil rigs and a range of other technology-based products, from jet engines to oil pipelines, have sensors attached (or, over time, built in) that would send real-time data to the companies should allow them to spot incipient problems at their earliest stages, in time to schedule early maintenance that would both reduce maintenance costs and reduce or even eliminate catastrophic failures. As I said before, this should be a win-win solution.

If problems still persisted after the companies had access to this real-time data, then more draconian steps could be required, such as also giving state and federal regulators real-time access to the same data — something that would be easy to do with IoT-based systems. There would have to be tight restrictions on access to the data that would protect proprietary corporate information, but companies that are chronic offenders would forfeit some of those protections to protect the public interest.

 

It’s Time for IoT-enabled “Real-Time” Regulation

Pardon me, but I still take the increasingly-unfashionable view that we need strong, activist government, to protect the weak and foster the public interest.

That’s why I’m really passionate about the concept (for what it’s worth, I believe I’m the first to propose this approach)  that we need Internet of Things enabled “real-time regulation” that wouldn’t rely on scaring companies into good behavior through the indirect means of threatening big fines for violations, but could actually minimize, or even avoid, incidents from ever happening, while simultaneously improving companies’ operating efficiency and reducing costly repairs. I wrote about the concept in today’s O’Reilly SOLID blog — and I’m going to crusade to make the concept a reality!

I first wrote about “real-time” regulation before I was really involved in the IoT: right after the BP Gulf blow-out, when I suggested that:

The .. approach would allow officials to monitor in real time every part of an oil rig’s safety system. Such surveillance could have revealed the faulty battery in the BP rig’s blowout preventer and other problems that contributed to the rig’s failure. A procedure could have been in place to allow regulators to automatically shut down the rig when it failed the pressure test rather than leaving that decision to BP.”

Since then I’ve modified my position about regulators’ necessarily having first-hand access to the real-time data, realizing that any company with half a brain would realize as soon as they saw data that there might be a problem developing (as opposed to having happened, which is what was too often the case in the past..) would take the initiative to shut down the operation ASAP to make a repair, saving itself the higher cost of dealing with a catastrophic failure.

As far as I’m concerned, “real-time regulation” is a win-win:

  • by installing the sensors and monitoring them all the time (typically, only the exceptions to the norm would be reported, to reduce data processing and required attention to the data) the company would be able to optimize production and distribution all the time (see my piece on “precision manufacturing“).
  • repair costs would be lower: “predictive maintenance” based on real-time information on equipment’s status is cheaper than emergency repairs.
  • the public interest would be protected, because many situations that have resulted in disasters in the past would instead be avoided, or at least minimized.
  • the cost of regulation would be reduced while its effectiveness would be increased: at present, we must rely on insufficient numbers of inspectors who make infrequent visits: catching a violation is largely a matter of luck. Instead, the inspectors could monitor the real-time data and intervene instantly– hopefully in time to avoid an incident.

Even though the IoT is not fully realized (Cisco says only 4% of “things” are linked at present), that’s not the case with the kind of high-stakes operation we’re most concerned with.  GE now builds about 60 sensors into every jet, realizing new revenues by proving the real-time data to customers, while being able to improve design and maintenance by knowing exactly what’s happening right now to the engines.  Union Pacific has cut dangerous and costly derailments due to bearing failures by 75% by placing sensors along the trackbed.

As I said in the SOLID post, it’s time that government begin exploring the “real-time regulation” alternative.  I’m contacting the tech-savvy Mass. delegation, esp. Senators Markey and Warren, and will report back on my progress toward making it a reality!

http://www.stephensonstrategies.com/">Stephenson blogs on Internet of Things Internet of Things strategy, breakthroughs and management