ELEMENT OVERVIEW
Managing changes to processes over the life of a facility is one of nine elements in the RBPS pillar of managing risk. This chapter describes the management practices involving (1) the recognition of change situations, (2) the evaluation of hazards, (3) the decision on whether to allow a change to be made, and (4) necessary risk control and follow-up measures. Section 15.2 describes the key principles and essential features of a management system for the MOC element. Section 15.3 lists work activities that support these essential features and presents a range of approaches that might be appropriate for each work activity, depending on perceived risk, resources, and organizational culture. Sections 15.4 through 15.6 include (1) ideas for improving the effectiveness of management systems and specific programs that support this element, (2) metrics that could be used to monitor this element, and (3) management review issues that may be appropriate
for MOC.
What Is It?
The MOC element helps ensure that changes to a process do not inadvertently introduce new hazards or unknowingly increase risk of existing hazards (Refs. 15.1 and 15.2). The MOC element includes a review and authorization process for evaluating proposed adjustments to facility design, operations, organization, or activities prior to implementation to make certain that no unforeseen new hazards are introduced and that the risk of existing hazards to employees, the public, or the environment is not unknowingly increased. It also includes steps to help ensure that potentially affected personnel are notified of the change and that pertinent documents, such as procedures, process safety knowledge, and so forth, are kept up–to-date.
Why Is It Important?
If a proposed modification is made to a hazardous process without appropriate review, the risk of a process safety accident could increase significantly.
Where/When Is It Done?
MOC reviews are conventionally done in operating plants and increasingly done throughout the process life cycle at company offices that are involved with capital project design and planning. MOC reviews should be done for bona fide “changes” – not for replacements-in-kind (RIKs).
Who Does It?
An individual originates a change request. Qualified personnel, normally independent of the MOC originator, review the request to determine if any potentially adverse risk impacts could result from the change, and may suggest additional measures to manage risk. Based on the review, the change is either authorized for execution, amended, or rejected. Often, final approval for implementing the change comes from another designated individual, independent of the review team. A wide variety of personnel are normally involved in making the change, notifying or training potentially affected employees, and updating documents affected by the change.
What Is the Anticipated Work Product?
The main product of an MOC system is a properly reviewed and authorized change request that identifies and ensures the implementation of risk controls appropriate to the proposed change. Ancillary products include appropriate revisions or updates involving other RBPS activities, such as modifying process safety information, and change communication/training. Outputs of the MOC element can also be used to facilitate the performance of other RBPS elements. For example, approved change requests are necessary to determine when some readiness activities are performed.
How Is It Done?
Organizations usually have written procedures detailing how MOC will be implemented. Such procedures apply to all work that is not determined to be RIK. The results of the review process are typically documented on an MOC Review form. Supplemental information provided by system designers to aid in the review process is often attached to the MOC review form. Once the change is approved, it can be implemented. Potentially affected personnel are either informed of the change or provided more detailed training, as necessary, prior to startup of the change. Follow-on activities, such as updates to affected process safety information and to other RBPS elements, are assessed to identify which are required before startup, and which may be deferred until after startup. All such activities are tracked until completed.
Higher risk situations usually dictate a greater need for formality and thoroughness in the implementation of an MOC protocol, for example, a detailed written program that specifies exactly how changes are identified, reviewed, and managed. Companies having lower risk situations may appropriately decide to manage changes in a less rigorous fashion, for example, through a general policy about managing changes that is implemented via informal practices by trained key employees. Facilities that exhibit a high demand rate for managing changes may need greater specificity in the MOC procedure and a larger allocation of personnel resources to fulfill the defined roles and responsibilities. Lower demand situations can allow facilities to operate an MOC protocol with greater flexibility. Facilities with a sound process safety culture may choose to have more performance-based MOC procedures, allowing trained employees to use good judgment in managing changes in an agile system. Facilities with an evolving or uncertain process safety culture may require more prescriptive MOC procedures, more frequent training, and greater command and control management system features to ensure good MOC implementation discipline.