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Outline
What is Management of Change (MOC) Why do we need MOC Recognizing Change The MOC Program
Main Elements Operation Keys to Success
Management of Change
Policies and procedures which ensure that changes do not result in operations outside of established safety parameters Essential element in a plants process safety system Managing change can mean managing potential incidents
Focus of MOC
To prevent catastrophic accidents and to properly evaluate the concerns of safety and health and to accomplish this review in a timely manner.
History of MOC
Early 60s - Formal procedures first introduced in the nuclear power and defense industries. 1976 - First mention of use within chemical industry at Loss Prevention Symposium 1985 - CCPA pamphlet, Essential Components of Safety Assessment Systems 1990 - API recommended practice Management of Process Hazards 1992 - OSHA 1910.119, Process Safety Management of Highly Hazardous Chemicals
In Hindsight ...
A proper MOC procedure could have prevented this accident. One of Main recommendations from inquiry
Any modification should be designed, constructed, tested, and maintained to the same standards as the original plant.
What is Change?
Most difficult part of Management of Change is recognizing change. Need to be able to distinguish between a change that requires approval using the MOC procedure and one that does not.
Recognizing Change
5-10 potentially high risk
Replacements-in-kind
Def. - a replacement that satisfies the design specifications. Examples
raising reactor temp. within safe operating envelope replacing equipment or piping meeting the same specifications as the original
Change
Change is an alteration or adjustment to any component, variable or property within an existing system (except those within clearly defined boundaries or responsibilities). Examples
changes that alter production rates changes involving safety relief or vent systems deteriorating materials
Change or Replacement-in-kind?
Changing metallurgy of a piping system. Recalibrating instruments Operating with a heat exchanger out of service Replacement of gate valves with ball valves (within the plant valve specifications)
Emergency Changes
Sometimes you have no choice and you have to make a change without going through the proper approval process. Need a contingency plan Evaluate using limited skills and resources focusing on immediate risk only. When normal operations resume implement a full MOC evaluation.
Identification System
Screening process for identifying changes.
Includes risk ranking process based on effect item could have on safety of process
Requires clear, written, definition of system boundaries and what constitutes change
Training
Anyone who could affect a change must be properly trained in the Management of Change system Commitment from all levels of management and staff
Auditing
Ensures system is working as it should MOC system should be constantly evolving and improving in efficiency and effectiveness Verifies changes are assessed accurately More often while the system is new to ensure all the bugs are found
IDENTIFY CHANGE
LOW
MEDIUM/ HIGH
REVIEW WITH TEAM LEADER
UNCERTAIN
LOW RISK
APPROVAL
IMPLEMENT CHANGE
FOLLOW-UP
MOC Form
A MOC form is used by most companies to guide employees through the procedure The MOC form should include:
Description, purpose, and tech. basis for the change Assigned level of risk Safety, Environmental, and Health impacts Necessary time period for the change Authorization for the proposed change Interfaces with the PSSR program
Ranking changes
Must delineate changes
small medium large
Dont manage all changes with same rigor Hazard analysis method and level of approval dependent on type of change.
Risk Matrix
Severity of Change
Low
Degree of Hazard Risk Level 1 2 3 4 Low High Type of Safety Review Simple Checklist What-if Checklist FMEA or HAZOP analysis HAZOP with consequence analysis Risk Level 1 Risk Level 3
High
Risk Level 2 Risk Level 4 Authorization Shift Supervisor Unit Supervisor Area Supervisor Plant manager
Management Support
Vital element in success of MOC system Honor your commitment
if an employee follows the system and the change is approved - then implement change!!
Important to show full support so that employees understand the benefits and dont feel like you dont trust their judgement.
Stakeholder Involvement
Essential to keep stakeholders informed throughout the MOC process.
will prevent them from putting up road blocks later.
Simplicity
A modest MOC system that is regularly used and works is much better than an elaborate, sophisticated system with an impeccable paper trail that is occasionally winked at, bypassed, or sometimes totally ignored.
Roy E. Sanders
Lessons Learned
Dont focus solely on modifications. Dont have unnecessarily tight equipment specifications. Applies to all process units, not just those containing flammable or toxic substances. Make sure there is easy access to documentation.
Conclusions
Improper plant modifications have been a major cause of chemical plant accidents. A formal method to deal with change will prevent future accidents from occurring. Change is unavoidable in industry
all organizations should have a MOC program.