036

Title: Management of Change
Freeport Site Function: Ecology & Safety

Procedure No.: BCF020.036 Page: 1 of 12
Reviewed: 07/16 Effective: 07/16 Supersedes: 08/14
Preparer: Owner: Approver:
EHS Team Leader or Designee Director, Environ., Health, & Safety SVP & Gen. Mgr., Freeport
REVISION HISTORY
Revision
Date Number Details of Change
07/26/16 8 Section 5.6.2 added
Att. B added I&E review
Att. D updated
Minor changes per MOC 0117-EHS-16-1140
08/13/14 7 Sections 4.4, 4.5, 4.6, 4.7, and 5.3.10 – added

Section 5.3.6 reworded to remove requirement to use Risk Level Assessment
05/05/14 6 Sections 3.1 and 8.0 – added reference to new standard BCF020.027, Alarm and
Interlock Management
09/11/13 5 Sect. 4.2 added Change Requestor or designee Sect. 4.3 specified differences
between Prod. Exec. Mgr. & Sr. Prod. Mgr.
Sect. 4.6 – 4.8 added
Sect. 5.0 added including capital projects that have undergone a Step Review
Sect. 5.3.3 added
Sect. 5.3.4.1 added last sentence
Sect. 5.3.9 updated to reflect use of Mode of Failure
Sect. 5.5.2 added last sentence
Sect. 5.7.3 added
Sect. 5.8 temporary change requirements modified
Att. A & B updated, Att. C added
Other minor changes as shown in MOC 0117-EHS-13-0817
02/19/13 4 Add EHS Team Leader signoff to Section 6.0 Variance.
10/19/12 3 Added Section 6.0 for requirements for using MOC Database to obtain approval
for deviations (variances) from Safety Procedures.
Added information to standard, Section 5.4.2, about the “new” checklists under
the Definitions button of Tab 4; Complete Prior to Start-Up section for questions
4, 5, 24. The checklists were designed to help MOC writer determine if additional
reviews are needed.
Updated review procedure for New Chemicals
09/30/08 2 Changed Organization Titles
Updated review procedure for new chemicals.
Changed Organizational Titles
Add additional exception to 5.1 A minor change is made to a Standard or

Procedure that does not affect the contents (i.e. updates to phone numbers).
03/16/07 1

Procedure was completely re-written to comply with the use of the Lotus Notes
Change Manager Database.
Safety Standard #27: Reactive Chemicals was deleted and New Chemicals
Environmental Review Instructions and Environmental Evaluation Form were
attached in the MOC procedure.
An Environmental Change Notification was added to help ensure that changes to

processes will not inadvertently create non-compliance with Air Permits (attached
in BCF020.036).

1.0 PURPOSE
The Management of Change (MOC) system is intended to ensure that the safety, health,
and environmental impact of all modifications to processes, equipment, and procedures
(other than “replacement in kind”) are identified and reviewed before the implementation
of the change.
2.0 SCOPE
This procedure outlines the requirements for the Management of Change (MOC) and
Pre-Start-Up Safety Review (PSSR) processes. (See BCF020.025 for more details on
the PSSR process.) It is intended for use with the Lotus Notes Change Manager
database system.
This procedure does not apply to replacement-in-kind.
3.0 DEFINITIONS
3.1 Change – a variation in the technology of manufacturing, process chemicals, and

process equipment, or an adjustment in the procedures of operating the process and
related equipment or in the organization of the department that can affect safety, the
environment, quality, or efficiency; Examples of changes are:
• Batch Plant Operations change – re-configuring a process to produce a

different product does not require an MOC provided that:
• The different product has previously been produced in the recent
past and the process for that product has undergone a review for
safety.
• The standard operation procedure and training are in place for how
to manufacture the different product.
• A standard operating procedure is in place, including appropriate
documentation requirements, to outline the steps necessary to
rearrange the equipment to produce the different product.
• Chemical/Technology changes – include modification of operating

conditions to outside of predefined safe operating limits, alarm or interlock
set point revisions, PLC software revisions, interlock logic revisions,
introduction of new chemicals, chemical substitution, chemical re-
introduction (Reference BCF020.027, Alarm and Interlock Management.)
• Deviation (Variance) from Safety Procedure(s) change – inconsistency

in how a procedure or process has been established and the way the
procedure or process is able to be done
• Emergency change – immediate actions used to avoid; or control a

spontaneous emergency situation

• Equipment changes – include new piping/equipment, piping

rearrangements, equipment revisions, new materials of construction, or
design parameters, impairment of fire water systems, impairment of alarm
systems
• Facility change – includes buildings, containers, process/emergency

equipment location, or equipment, which contain a process
• Personnel/Organizational changes – include a change in the number of

operations, instrument/electrical or maintenance support, or contractor for
the site or unit, and absence from job for extended period
• Procedural changes – include standard operating procedures, emergency

procedures, safe work procedures, temporary operating procedures,
maintenance/inspection procedures, maintenance/ inspection procedures
or development of a new procedure for new equipment installations
• Replacement-in-Kind – an item, equipment, chemical, procedure etc. that

meets the design specification of the item it is replacing
Management of Change is not required. Examples are:
• equipment (vessels, agitators, heat exchangers, etc.) fabricated

exactly to the original design and specification or existing approved
design and located in the same position as the original
• equipment and materials that are manufactured by an approved

supplier to a standard specification, such as bolts, gaskets, flanges,
steam traps, piping, insulation, structural steel
• instrumentation (transmitters, pressure and temperature gauges,

etc.) of the same specification and range, and purchased from an
approved supplier
• electric motors, fuses, and circuit breakers of the same specification

from an approved supplier
• replacement of piping with the same size, material, flange make-up,

and routing as the existing
• Temporary change – planned for a limited duration; such as, a trial or

evaluation or by-pass of a safety system for maintenance
4.0 RESPONSIBILITIES
4.1 All employees have the responsibility to:


- Recognize a change before initiating.

- Initiate the MOC, per this policy.
- Assist in making changes.
- Participate in training.
- Provide input in maintaining a safe working environment.
4.2 Change Requestor has the responsibility to:

- Initiate the MOC/PSSR by defining the change and reason for the change.
- Assign MOC/PSSR Coordinator (can be the requestor).
- Forward to the appropriate person (OM, SM or designee) for approval to proceed.
- Participate in the technical review if required.
- Complete hazards analyses or risk assessment.
- Participate in PSSR (Change Requestor or designee).
- Complete pre- and post-start-up safety review checklist items and assign action
items.
4.3 Production Director and Production Execution Manager have the overall responsibility
to:
- Solicit employees’ participation by getting their input on changes.
- Determine if a technical review is required and assigns technical reviewers.
- Ensure that all items on the MOC/PSSR checklists have been completed as
required before implementation of the change.
- Give final approvals to implement the change. The Production Execution Manager
will be set up in the system as the default Final Approver, and the Sr. Production
Manager/Director will be set up to be copied on Tab 2. The Production Execution
Manager may serve as the final approver except for the scenarios below, which
require Sr. Production Manager/Director approval.
• deviations from safety procedures (Section 6.3)
• modifying relief devices or SIS
• making safety devices that protect from B and C risks inoperative, including
PSVs, PVRVs, and SIS (BCF020.009)
• changes deemed high or critical process risk per Mode of Failure analysis
• capital projects requiring a Step 3 review (because of hazards, not because
the unit maintains evergreen PHAs)
• changes determined by the Sr. Production Manager as needing his
approval
- Ensure affected personnel are trained in the MOC requirements and changes.
4.4 Mechanical Services Manager or delegates have the overall responsibility to:
- Give final approvals to implement site maintenance procedure changes.
4.5 Area Maintenance Managers or delegates have the overall responsibility to:
- Give final approvals to implement area maintenance procedure changes.

4.6 EHS Team Leaders or delegates have the overall responsibility to:
- Give final approvals to implement EHS procedure changes.
4.7 Lab Service Manager or delegate has the overall responsibility to:
- Give final approvals to implement lab changes that are not approved by
Production.
4.8 MOC Coordinator has the responsibility to:

- Coordinate completion of the MOC approval/checklist items as assigned.
- Follow-up on sign-off of change requirements on the MOC form.
- Get or verify that final approval has been given before implementing the change.
- Initiate and verify completion of required items on the MOC checklist.
4.9 Technical Reviewers have the responsibility to:

- Review change requests and sign (if signature is required) the form
acknowledging completion of the review and acceptance of the change.
4.10 Learning & Development Coordinators have the responsibility to:

- Assist with training for an MOC, including assisting with determining who needs
MOC training and the proper training method.
- Assist in ensuring that all personnel are trained before operating the modified
process.
- Assign MOC training to personnel in new roles.
4.11 Shift Supervisors have the responsibility to:

- Ensure that all personnel are trained before operating the modified process.
4.12 Typical job titles associated with each MOC role are shown in Attachment C. Each
unit should create a unit-specific version of Attachment C with names for ease of use.
5.0 PROCEDURE
The Lotus Notes Change Manager database shall be used to review and document all
capital and non-capital (expense) changes and PSSRs defined under 3.1 (See Exceptions
under 5.1.).
5.1 The approval process for changes must be followed and documented using the
Change Manager database.
Exceptions:
• Emergency type changes can be verbally authorized (approved) by supervision

and then documented, reviewed, and formally approved after the situation has
stabilized. An “Emergency Change” form is available and can be printed from
the Change Manager database by accessing the database and clicking “?”
(Help) In the menu bar.

• Replacement-in-Kind
• A minor change is made to a standard or procedure that does not affect the
contents (i.e., updates to phone numbers).
• A batch operation as meets the provisions outlined in 3.1
• Temporary fire system impairment lasting fewer than 24 hours can be
documented and communicated using a Fire Protection System Impairment
Procedure (BCF020.045) and unit communication.
5.2 MOC ORIGINATION: INITIATING A CHANGE
5.2.1 Any person can initiate or recommend that a change be made. Minimal
information, specifically, a description of the proposed change, the
technical basis of the proposed change, expected impact on the safety
and health of the employees affected by the proposed change, and the
duration of the change should be provided. Any change will require
completion of Tab 1, the “Definition” section of the Management of
Change Form.
5.3 MOC INITIATION, APPROVAL TO PROCEED AND RISK ASSESSMENT

(TABS 1, 2, &3)
5.3.1 The MOC Initiator and the Change Coordinator are responsible for
implementing the entire MOC procedure. The Initiator or Change
Coordinator evaluates the proposed change and identifies information that
must be collected for the particular change.
5.3.2 The Initiator assigns the Change Coordinator (can be the MOC Initiator)
and describes the change and the justification for the change. If the
change is temporary, the Initiator sets the expiration date and submits the
MOC to the Approver (Tab 1).
5.3.3 It is a best practice to include the project number in the title for capital
projects for easy searching.
5.3.4 The Approver determines the level of review required for the MOC and if
necessary assigns the appropriate personnel to conduct and participate in
the review (Tab 2).
Note: A change made may affect Occupational Safety, (i.e., PPE

requirements), Industrial Hygiene (i.e., MSDS addition), Process
Safety (i.e., relief valve sizing), Electrical Area Classification and
associated documentation (i.e. updates to the affected areas and
embedded flammable chemical table), Environmental (i.e... air or
water permitting).

5.3.4.1 To help determine if an air permit is needed or an existing permit

must be amended because of a change in the unit, an
Environmental Change Checklist has been developed. (See
Attachment A.) The completed form should be attached to the
MOC. Construction on new or modified equipment cannot begin
until any necessary air permits are issued.
5.3.4.2 To assist with the evaluation for addition and use of new chemical,
New Chemical Environmental Review Instructions and an
Environmental Review Form have been developed. (See
Attachment B.) The completed review forms should be attached to
the MOC.
5.3.5 It should also be determined in the initial review, based upon the impact
of the change, if additional technical or specialized reviews (HAZOP,
Environmental, OS/IH, Legal, Customer Notification, etc.) are necessary
to evaluate the feasibility of the proposed change.
5.3.6 The following information should be evaluated during the Initial Review:
- technical feasibility of the proposed change
- justification and necessity of the change
- adequate design information/specifications to perform a valid review
(based on group judgment and knowledge of the process)
- if modifications to written procedures are required (including time limit for
temporary changes)
- the expected duration of the change for temporary changes
- review of relevant PHA to verify that proposed change does not violate
existing safeguards or create a potential hazard
- a risk assessment in the Change Manager database, Tab 3, Risk
5.3.7 Documentation of the Initial Review should be maintained with the MOC.
If a formal meeting is held, minutes from this meeting can document the
topics discussed, the decisions reached, and the names of the reviewers
(Tab 2).
5.3.8 The Approver then either “approves” to proceed with the change, “denies”
the change, or puts the change on “hold” because of a concern. If the
Approver has a concern, he completes the “Concern Page” and assigns a
responsible person. If the concern is satisfied, the MOC is approved. At
this time the Approver can change the MOC Coordinator if necessary (Tab
2).
5.3.9 All MOCs/PSSRs shall include an assessment of the impact to safety,

health, and the environment. The goal of the assessment is to determine
what and whom the proposed change will affect. A Mode of Failure review

is recommended for non-capital projects because it allows for a thorough

evaluation of changes, regardless of scope. This review can be done
formally or informally, depending upon the Risk Level.
Level Degree of Risk -- Failure of Type of Hazard Evaluation Approval

Proposed Change may result in
Low Risk Onsite potential for minor injuries DST - MOC Coord. & Assigned Technical PEM or
Reviewers (minimum of 2, MOC Coord. designee
& one Technical Reviewer, which can be
the PEM)
Medium Risk Onsite potential (or likely hood) for lost DST – Formal Hazard evaluation - EHS, PEM
time or serious injuries Technician, Instr. &/or Mech. Eng. (as
needed) and Process Eng. (or
equivalent). Other Technical persons as
needed. Daily Production meetings
could be adequate depending on
attendance.
High Risk Potential for one or more Fatalities Full Hazard evaluation. Same as above Prod. Mgr./Dir.
but may include Site EHS, or other
outside experts. Prod. Mgr./Dir. to
decide with DST or TES Technical
Personnel.
Critical Process Major process safety incident Full Hazard evaluation. Same as above Prod Mgr./Dir.
but may include Site EHS, Corporate
others. Prod. Mgr./Dir. and PEM to
decide needed involvement.
Risk Level Assessment is not a hazard evaluation. If Risk Level

Assessment is used, a hazard evaluation such as Mode of Failure, Step
Review, or PHA must also be used.
5.3.10 Attachment D shall be used for new or relocated portable buildings,

containers, and tents unless out of scope per the Scope FAQ in Att. D.
5.4 MOC/PSSR CHECKLIST (TAB 4)
5.4.1 All questions in the Pre-Start-up and Post-Start-up sections will be

answered YES or NO. One can add extra action items.
5.4.2 Question Numbers 4, 5, and 24 have checklists associated with them

under the Definitions button (gray menu at top of page) to help determine if
additional reviews or action items are needed for Environmental, OSIH, or
Process Safety because of the change.

5.4.3 YES answers will be assigned as an Action Item. Final Approval for start-
up cannot be submitted until the Pre-Start-up Action Items are complete.
All Pre-Start-up Action Items shall be completed before start-up of the
change.
5.5 MOC/PSSR TRAINING (TAB 5)
5.5.1 Training documentation is automatically maintained in the Lotus Notes

Change Manager system when the electronic signoff feature of the
Change Manager system is used.
5.5.2 In the event that another means of training is used, evidence that those
affected by the change have been informed/trained MUST be maintained.
A sign-up sheet may be used and attached on the MOC Training Page.
NOTE: All signatures do NOT have to be signed off to start up. Sign-off
before start-up may not be possible because of shift schedules.
Employees are required to be informed/trained and signed off
before operating or working on equipment or processes that have
been changed. Learning & Development Coordinators are
responsible for setting up a process to ensure employees that are
trained before operating the impacted processes.
5.6 MOC/PSSR PRE-START-UP SAFETY REVIEW (TAB 6)

The PSSR team should review the status of any action items/open issues from
the MOC, Step 3, PHA, or EHS reviews with the team. In addition, the status of
PSSR action items should be reviewed. (See BCF020.025 for details of the
PSSR procedure.)
5.6.1 A PSSR must be completed or waived before approval is given to start-up

a change.
5.6.2 When restoring a temporary change back to the original configuration,

conduct another PSSR if a PSSR was needed for the change to the
temporary condition.
5.6.3 The PSSR procedure and the long form are in BCF020.025.
5.7 MOC/PSSR APPROVAL TO START-UP (TAB 7)

Approval to start-up must be obtained from the Unit/Department approver before
the change can be implemented. In addition, the Final Approver can require
additional approvers as necessary.
5.7.1 Determine the start-up approvers required for the change and send a
request for approval to the specified personnel.

5.7.2 All Pre-Start-up Action Items must be completed before the request for
start-up approval can be submitted.
5.7.3 If only one person approves for start-up, he/she cannot be the same
person as the Change Coordinator.
5.8 MOC TEMPORARY CHANGE (TAB 8)

Temporary changes must follow the full management of change procedure. If a
temporary change exists for >90 days, a refresher training frequency should be
considered. Temporary change must follow one of the following three completion
options:
5.8.1 “Change Removed” – all affected personnel notified by email or other

appropriate means
5.8.2 “Extend Expiration Date” – all affected personnel notified by email or

other appropriate means of the new expiration date
5.8.3 “Make Permanent” – a new change will be created, and certain

information copied into the new document
5.9 MOC/PSSR CLOSE-OUT

After approval is obtained to start-up the change, the Change Coordinator or
other designated person will sign off the change as complete.
6.0 DEVIATION (VARIANCE) FROM ESTABLISHED SAFETY PROCEDURES
6.1 An assessment must be conducted to verify that a required task cannot be

accomplished in any other way or time without deviating from the established
procedure (not a matter of convenience).
6.2 The MOC shall contain the assessment in addition to the following information:
• the portion of the Safety procedure(s) (standard(s)) that require(s) deviation
• why the task cannot be done in accordance with the established Safety
procedure (standard)
• the actions that are being taken to manage the risk and protect personnel,
environment, and property (potential risks and the protective measures)
• attachment of the approved procedure that is to be followed (including PPE if
applicable)
• the plans that are in place or will be put into place to prevent the need to vary
from the established procedures in the future
6.3 The Production Execution Manager may sign the approval to proceed, but the
start-up approval must be given by the Sr. Director/Manager level or above and
EHS Hub Team Leader.
7.0 TRAINING

Training is required when:

• employee is initially assigned responsibilities for recognizing changes
• every three (3) years,
• changes are made to the standard
• deviations to the requirements are identified
Additional training materials are available in Change Manager by clicking “?” (Help) and
choosing links titled “Link to Training Materials on Change Manager” and “Frequently
Asked Questions.” The online help section for Change Manager is a good resource for
questions concerning the Lotus Notes Change Manager database.
8.0 ATTACHMENTS/ RELATED DOCUMENTS
Attachment A: Environmental & I&E Evaluation Form

Attachment B: New Chemicals Environmental Safety Review Instructions
Attachment C: MOC Process Roles and Responsibilities
Attachment D: Portable Building, Container, and Tent Checklist
BCF020.027: Alarm and Interlock Management

036

Caricato da

Informazioni sul documento

Copyright

Formati disponibili

Condividi questo documento

Condividi o incorpora il documento

Opzioni di condivisione

Hai trovato utile questo documento?

Questo contenuto è inappropriato?

Copyright:

Formati disponibili

036

Caricato da

Copyright:

Formati disponibili

Title: Management of Change

Freeport Site Function: Ecology & Safety

08/13/14 7 Sections 4.4, 4.5, 4.6, 4.7, and 5.3.10 – added

02/19/13 4 Add EHS Team Leader signoff to Section 6.0 Variance.

Updated review procedure for New Chemicals

09/30/08 2 Changed Organization Titles

Updated review procedure for new chemicals.

Changed Organizational Titles

Add additional exception to 5.1 A minor change is made to a Standard or

Freeport Site Function: Ecology & Safety

An Environmental Change Notification was added to help ensure that changes to

Freeport Site Function: Ecology & Safety

This procedure does not apply to replacement-in-kind.

3.1 Change – a variation in the technology of manufacturing, process chemicals, and

• Batch Plant Operations change – re-configuring a process to produce a

• Chemical/Technology changes – include modification of operating

• Deviation (Variance) from Safety Procedure(s) change – inconsistency

• Emergency change – immediate actions used to avoid; or control a

Freeport Site Function: Ecology & Safety

• Equipment changes – include new piping/equipment, piping

• Facility change – includes buildings, containers, process/emergency

• Personnel/Organizational changes – include a change in the number of

• Procedural changes – include standard operating procedures, emergency

• Replacement-in-Kind – an item, equipment, chemical, procedure etc. that

• equipment (vessels, agitators, heat exchangers, etc.) fabricated

• equipment and materials that are manufactured by an approved

• instrumentation (transmitters, pressure and temperature gauges,

• electric motors, fuses, and circuit breakers of the same specification

• replacement of piping with the same size, material, flange make-up,

• Temporary change – planned for a limited duration; such as, a trial or

4.1 All employees have the responsibility to:

Freeport Site Function: Ecology & Safety

- Recognize a change before initiating.

4.2 Change Requestor has the responsibility to:

Freeport Site Function: Ecology & Safety

4.8 MOC Coordinator has the responsibility to:

4.9 Technical Reviewers have the responsibility to:

4.10 Learning & Development Coordinators have the responsibility to:

4.11 Shift Supervisors have the responsibility to:

• Emergency type changes can be verbally authorized (approved) by supervision

Freeport Site Function: Ecology & Safety

5.2 MOC ORIGINATION: INITIATING A CHANGE

5.3 MOC INITIATION, APPROVAL TO PROCEED AND RISK ASSESSMENT

Note: A change made may affect Occupational Safety, (i.e., PPE

Freeport Site Function: Ecology & Safety

5.3.4.1 To help determine if an air permit is needed or an existing permit

5.3.9 All MOCs/PSSRs shall include an assessment of the impact to safety,

Freeport Site Function: Ecology & Safety

is recommended for non-capital projects because it allows for a thorough

Level Degree of Risk -- Failure of Type of Hazard Evaluation Approval

Risk Level Assessment is not a hazard evaluation. If Risk Level

5.3.10 Attachment D shall be used for new or relocated portable buildings,

5.4 MOC/PSSR CHECKLIST (TAB 4)

5.4.1 All questions in the Pre-Start-up and Post-Start-up sections will be

5.4.2 Question Numbers 4, 5, and 24 have checklists associated with them

Freeport Site Function: Ecology & Safety

5.5 MOC/PSSR TRAINING (TAB 5)

5.5.1 Training documentation is automatically maintained in the Lotus Notes

5.6 MOC/PSSR PRE-START-UP SAFETY REVIEW (TAB 6)

5.6.1 A PSSR must be completed or waived before approval is given to start-up

5.6.2 When restoring a temporary change back to the original configuration,

5.7 MOC/PSSR APPROVAL TO START-UP (TAB 7)

Freeport Site Function: Ecology & Safety

5.8 MOC TEMPORARY CHANGE (TAB 8)