Work Management Part 4: Maintaining Asset Inventory Data and Drawings

JD Solomon Inc. specializes in strategic asset and work management support—bringing clarity to what you own, its condition, and its value.

Garbage in, garbage out. One of the biggest challenges organizations faces is maintaining accurate asset data and up-to-date drawings. These two foundational elements—what we own and how it’s documented—are important to the success of any asset management system. More importantly, they can easily be addressed as part of work management.

It’s Obvious Why It Matters

Smarter Planning and Better Decisions

Knowing what assets you have and their condition makes it easier to plan budgets, schedule maintenance, and respond to emergencies.

• Accurate asset data provides valuable insights into useful life, obsolescence, maintenance strategies, and the time required for ordering critical spare parts.

• Accurate drawings also help field staff understand layouts, components, and interconnections, reducing guesswork.

Improved Safety and Efficiency

Up-to-date working drawings and safety instructions help field crews work more efficiently and safely. For example, having electrical one-line diagrams readily available minimizes downtime and risk.

Compliance and Accountability

Regulatory agencies often require documented proof of system layouts and emergency provisions. A well-managed inventory and set of drawings ensure your organization stays in compliance and defends operations when needed.

Three Common Challenges

I have worked with hundreds of facilities and infrastructure organizations over the past 30 years. When I reflect on the most recent five or six organizations, the fundamental challenges for maintaining asset data and drawings remain the same.

1. Disconnected Systems

Many organizations store asset data and drawings in separate computer systems (databases). While we see fewer legacy spreadsheets these days and more centralized databases, the problem persists that maintaining links and data across platforms remains a significant challenge.

2. Unclear Ownership and Roles

Who decides what's considered a part versus an asset? Who updates the drawings after small system changes? These questions often go unanswered, resulting in stale data and outdated documents.

Everyone shouldn't hesitate when you ask the simple question, "Who owns the data?"

3. Resource Constraints

As more capital work is conducted through operations and maintenance (O&M), the people on the ground often lack the time and support to update drawings or maintain detailed asset inventory lists. These long-term issues get pushed to the back burner. From an information systems perspective, we’re much better at installing new systems than maintaining existing ones.

Three Practical Fixes

The fixes are not sexy when it comes to maintaining asset data and drawings. To use a football analogy, its blocking and tackling. To borrow a quote from a song by David Byrnes and the Talking Heads, "Same as it ever was."

A. Embed in Daily Workflows

Don't treat asset data and drawings as a separate task. Instead, make them part of routine inspections and PMs. Include checklists that confirm the presence of critical spares, safety instructions, and current drawings.

B. Clarify Roles and Policies

Establish who owns the responsibility for maintaining different types of data—tools, parts, assets, and drawings. Define what gets updated, when, and by whom. This clarity reduces confusion and helps spread the workload effectively.

C. Phase in with the CMMS Strategy

Maintaining asset data and drawings is a heavy lift, so don't try to do it all at once. Start small—maybe with one system or one facility—and phase it in. Add links to drawings and parts lists in your CMMS during later implementation stages, when your team is ready to do so.

Effectively Maintaining Asset Data and Drawings

Maintaining asset data and drawings may not seem urgent until something breaks or an inspector arrives. However, waiting until there's a crisis means missing opportunities, incurring increased costs, and taking on unnecessary risks. Treating inventory and drawing management as a key part of work management, and you’ll lay the groundwork for a safer, more efficient, and future-ready operation.

Need help getting started? JD Solomon Inc. specializes in strategic asset and work management support—bringing clarity to what you own, its condition, and its value.

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JD Solomon Inc. provides practical solutions for program development, asset management, and facilitation at the nexus of facilities, infrastructure, and the environment. Visit our Asset Management page for more information related reliability, risk management, resilience, and other asset management services.

Why Work Documentation in Maintenance and Reliability Matters

The key to work documentation is to keep it simple as possible.

Work documentation is tough. Most people prefer doing the work rather than doing the paperwork. However, work documentation is critical in keeping equipment and physical assets running smoothly. When done right, documenting the work helps the team stay organized, supports smart decision-making, and gets more of what you need from senior management. Work documentation is more than paperwork—it’s a foundation for long-term success.

Why Document Work?

There are three main reasons to document maintenance work: to show the need for more staff, to protect yourself (CYA—cover your assets), and to enable useful analysis later.

Obtain More Resources

First, well-documented work can reveal when your team is stretched too thin. If your records show consistently high work hours and backlogs, it becomes easier to justify hiring more help. Without those records, you’re stuck with just your word—which may not be enough.

Protect Yourself

Second, documentation protects you. If something breaks or goes wrong, you want to be able to show what work was done and when. It’s proof that you followed procedures and managed things responsibly. Documentation is important when safety, compliance, or money is on the line.

Identify Trends

When maintenance data is collected over time, it becomes useful for spotting patterns. For example, a pump may fail every 18 months. Without documentation, you might miss that trend. But with good records, you can predict future failures and plan replacements before breakdowns happen.

Software Is Not Everything

Many people think work documentation is about having the right software. However, software is not the heart of the process. Structure and discipline related to following your business processes matter most.

Follow the Process

Work documentation should follow a consistent process. This includes logging what was done, when, by whom, and why. It also involves tracking the parts used, time spent, and any follow-up work needed. Everyone on the team needs to follow the same process so the data is useful and reliable.

Decide Who Owns the Work Documentation Process

Equally important is deciding who owns the process and the data. Is it the maintenance planner? The operations supervisor? A shared responsibility? Without clear ownership, things tend to slip through the cracks.

Make Sure Senior Management Cares

Here’s a tough question: does anyone in management care about the documentation? If not, it’s hard to make it a priority. Many organizations collect too much or the wrong kind of data. However, when leadership sees the value, especially in terms of dollars and downtime, they’re more likely to support the effort. And if senior management cares, most people down the line will care.

Forecasting and Big-Picture Thinking

One powerful use of work documentation is replacement forecasting. By using R&R (Repair and Replace) models, asset health models, and renewal forecasts, organizations can plan for the future instead of reacting to problems. This kind of forward-thinking makes it easier to budget for replacements and upgrades.

Use the Data

Some organizations feel good about their work documentation because most of the blanks are filled in the software. However, a lot of data is entered that is just plain wrong. The best way to test your data is to put it into a forecast.

Speak the Language of Senior Management

Importantly, R&R forecasts tie maintenance data to financial planning. Finances, and more specifically money, is the language of senior management and the board of directors. R&R forecasts help show what needs fixing and what it will cost if it's not fixed soon.

Keep It Simple

The key here is to keep it simple. Start with a simple spreadsheet, Make simplifying assumptions. Build complexity as your team becomes more comfortable with the process. Using your data at the simplest level will reveal many gaps.

Why Work Documentation Matters

Good work documentation is a strategic tool. It helps justify staffing, supports safety and compliance, improves planning, and saves money. Whether you're in a water utility, a factory, or a public works department, clear and consistent documentation makes your maintenance and reliability efforts more effective. In short, the effort makes your job easier in the long run. Work documentation matters.

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JD Solomon Inc. provides solutions for program development, asset management, and facilitation at the nexus of facilities, infrastructure, and the environment. Visit our Asset Management page for more information related reliability, risk management, resilience, and other asset management services. Subscribe for bi-monthly updates related to our firm.

How Big Are the Environmental Impacts in the SCOTUS Ruling in San Francisco v. EPA?

Permit requirements will need to become more specific based on the recent SCOTUS ruling (base image source: www.epochtime.com)

The recent U.S. Supreme Court decision in City and County of San Francisco v. Environmental Protection Agency has significant implications for wastewater dischargers and the environment. In short, the EPA must set specific, measurable discharge limitations that the permittee can control, and the NPDES permits must focus on clear, actionable discharge limits. Gone are the days when point source dischargers can help nebulous end-results in an open water body.

The Case

According to the Supreme Court of the United States (SCOTUS) opinion (March 4, 2025), “this case involves a challenge to “end-result requirements” permit provisions that do not spell out what a permittee must do or refrain from doing but instead make a permittee responsible for the quality of the water in the body of water into which the permittee discharges pollutants. “

The City of San Francisco operates two combined wastewater treatment facilities that process both wastewater and stormwater. During periods of heavy precipitation, the combination of wastewater and stormwater may exceed the facility’s capacity, and the result may be the discharge of untreated water, including raw sewage, into the Pacific Ocean or the San Francisco Bay.

In 1994, the EPA adopted its combine sewer overflow (CSO) Control Policy. The policy requires municipalities with combined systems to take prescribed measures and to develop and implement a Long-Term Control Plan. It is a two-phase permitting process. 

San Francisco's NPDES permit for its Oceanside facility was renewed without controversy for many years. However, in 2019, the EPA issued a renewal permit that added two end-result requirements.

1. Prohibits the facility from making any discharge that “contribute[s] to a violation of any applicable water quality standard” for receiving waters.

   
   

2. Provides that the City cannot perform any treatment or make any discharge that “create[s] pollution, contamination, or nuisance as defined by California Water Code section 13050.”

The County and City of San Francisco argued that both of these were not in accordance with the Clean Water Act. The Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for surface waters.

The basis of the CWA was enacted in 1948 and was called the Federal Water Pollution Control Act, but the Act was significantly reorganized and expanded in 1972. "Clean Water Act" became the Act's common name with amendments in 1972.

Section 1311 of the CWA is part of Subchapter III covers Standards and Enforcement.

The Supreme Court’s Opinion

The Supreme Court held in San Francisco’s favor on the primary issues.

1. Section 1311(b)(1)(C) does not authorize the EPA to include "end-result" provisions in NPDES permits. Determining what steps a permittee must take to ensure that water quality standards are met is the EPA's responsibility, and Congress has given it the tools needed to make that determination.

   
   

2. Section 1311(b)(1)(C) does not authorize permit requirements conditioning compliance on receiving water quality. The provision’s text, structure, and context support this interpretation.

   
   

3. The agency has adequate tools to obtain needed information from permittees without resorting to end-result requirements. Its reliance on the Combined Sewer Overflow Policy is misplaced as that policy authorizes narrative limitations but not end-result requirements. And concerns about disrupting general permits are unfounded given that narrative limitations remain available.

Barrett’s Dissent - discoloration, scum, and toilet paper

I like to look at dissenting opinions for insights. This is especially true then the dissenting opinion is from someone normally in the majority.

Justice Amy Coney Barrett, a Trump Appointee, wrote the dissenting opinion. These are a few of her summary comments:

On Supplemental Limitations

The City's permit thus tracks the structure of §1311(b). It restrains discharges initially through technology-based effluent limitations, as required by §1311(b)(1)(A). But because the effluent limitations may be insufficient to ensure that California's water quality standards are met, the permit contains supplemental limitations, as required by 1311(b)(1)(C).

The concern that the technology-based effluent limitations may fall short is on display in this case—discharges from components of San Francisco’s sewer system have allegedly led to serious breaches of the water quality standards, such as “discoloration, scum, and floating material, including toilet paper, in Mission Creek.” The receiving water limitations imposed under 1311(b)(1)(C) are included to ensure that such breaches do not occur.

All Discharges Are Presumptively Unlawful

Under the old system, the United States could bring abatement actions only after the pollution had already occurred. A glaring problem with this approach is that an ex-post enforcement regime does not adequately deter polluters or prevent pollution. Making matters worse, this regime involved “cumbrous enforcement procedures” that made it next to impossible to bring abatement actions.

Congress chose a different regulatory model when it adopted the Act in 1972. The Act renders all discharges presumptively unlawful. Then, under the current ex ante permitting regime, EPA authorizes only those discharges that comply with the Act. Should a permittee fail to comply with the terms of its permit, EPA has broad authority to sue.

What The SCOTUS Opinion Means to Wastewater Dischargers and the Environment

​The recent U.S. Supreme Court decision in City and County of San Francisco v. Environmental Protection Agency has significant implications for wastewater dischargers and the environment. In short, the EPA must set specific, measurable discharge limitations that the permittee can control and the NPDES permits must focus on clear, actionable discharge limits. Gone are the days when point source dischargers can help nebulous end-results in an open water body.

Wastewater will need to ensure their operations comply with the specific effluent limitations outlined in their NPDES permits. Wastewater dischargers may need to work with permitting authorities to revise existing permits to remove or replace any "end-result" provisions with clear, actionable discharge limits. State regulatory agencies will need to develop clear guidelines and methodologies for translating water quality standards into precise effluent limitations within permits.

References

• City and County of San Francisco v. Environmental Protection Agency, No. 23-753 (U.S. March 4, 2025).

• USEPA CWA website

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JD Solomon Inc. provides solutions for program development, asset management, and facilitation at the nexus of facilities, infrastructure, and the environment. Visit our Environmental page for more information related reliability, risk management, resilience, and other asset management services. Subscribe for bi-monthly updates related to our firm.