1) Always Know What a Change is for the Facility | AIChE

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1) Always Know What a Change is for the Facility

Last updated December 2, 2020

Table of Contents

1) Always know what a change is for the facility

Why

  1. Defining a change triggers  the MOC process
    1. Understanding what is considered a change within your organization helps define the scope and boundary of the MOC process.
    2. Being able to interpret the definition of replacement in kind as it applies to each proposed change. If this interpretation is made incorrectly it can lead to inconsistent implementation and may adversely impact the safety of affected workers, the community, the environment or business continuity.  (1)​​​​​​
  2. Incidents –
    1. On October 9, 2012, a flash fire caused burn injuries to seven workers, including three who sustained third-degree burns at the US Ink/Sun Chemical Corporation ink manufacturing facility in East Rutherford, New Jersey.  Workers were drawn to a black ink mixing room by the initial flash of the fire from a bag dumping station and by a loud thumping noise from the rooftop. As the workers congregated at the doorway, they observed a small fire in the ductwork of a newly installed dust collection system above a process mixing tank. Suddenly, a large flash fire emerged from the pre-mix room and engulfed the seven employees in flames. A new dust collection system had been commissioned 4 days before the incident.  An MOC was not written for this new dust collector system as engineers and senior management considered the dust collector system as a replacement in kind for the old wet scrubber system.   In addition to not having written an initial MOC for the change, the original design of the dust collection system was modified.  The original design was intended strictly for dust collection but was modified before commissioning to include vacuum cleaning function.  This cleaning function had insufficient flow rate which restricted air movement and contributed to an accumulation of hazardous materials in the duct system.  (2)
    2. On June 13, 2013 an explosion and fire occurred at the William Olefin Plant in Geismar, Louisiana killing two employees.   The incident occurred during non-routine operational activities that introduced heat to the reboiler that was offline and isolated from its pressure relief device.   The heat increased the temperature of the liquid propane mixture that was confined within the reboiler.  This temperature rise resulted in a significant pressure rise in the vessel causing the shell of the reboiler to rupture, leading to a boiling liquid expanding vapor explosion (BLEVE) and fire, which killed two workers and injured 167 others.   One of the identified causes of the incident was the addition of car seals. Car seals were installed to lock open the propylene fractionator reboiler process valve to provide enough relief capability.  This change was made without preforming an MOC and evaluating if there was enough relief capacity.   (3)

How - General

  1. Develop and implement a written MOC process.
    1. Define when an MOC is required. Scope of the MOC system should define all types situations that should be addressed that can be foreseen. 
      1. The scope may include changes to process, equipment, operating and other procedures, utility systems and infrastructure.   (1)
      2. The scope may include MOC for personnel changes or sometimes separately as  MOOC ( Management of  Organizational Change).
      3. The scope should include additions and deletion to a process or its supporting systems.  (1)
      4. The scope may also include regulatory requirements and local needs
    2. Include examples of when MOC is required
      1. An MOC is required unless the change is a Replacement In Kind (RIK).  RIK is described as an item, which could be equipment, chemical, etc., that meets the design specification of the item it is replacing.  (1)
      2. A clear description of RIK should be clearly defined and understood to prevent errors and broad interpretation.   For example, replacing a gate valve with a globe valve would not meet the RIK description and thus would qualify as a change. 
      3. If a change affects operating procedures, sequence of operation, programming or controls, permitting or regulation of the process they would not meet the RIK description and thus would qualify as a change.
      4. Examples can be from home office or local facility. The most meaningful examples would be from the local facility.
    3. Include examples of when MOC is not required.
    4. Include a process to determine if MOC is required when in doubt. Many companies have a flow chart or checklist to help determine if the change meets the RIK definition.   If it does not meet the RIK description, then an MOC should be generated for the change.   When in doubt, write the MOC.   (1)​​​​​​
    5. Consider using multiple MOC procedures to effectively address all possible changes because a single process ( One size fits all)” MOC process does not always work efficiently.
      1. Ensure that all basic requirements of MOC are included in the multiple procedures. This should include the core parts of an MOC, i.e; the technical justification; known EHS impacts of the change; the approvals; informing affected personnel before operating the change; identification of whether the change is temporary or permanent.
      2. Examples :
        • Special MOC procedure for operating procedure changes
        • Special MOC procedure for installing pipe clamps
        • Special MOC procedure for adjusting equipment testing and inspection frequencies
        • Temporary MOC procedure for bypassing safety devices
  2. Train all facility personnel on when an MOC is required and when it is not required. Training provides guidance on expectations and roles within the MOC system.  It lays out the framework to how the MOC system works, what is considered a change and the review and approval process.  (4)

How - Operators and Maintenance

  1. Understand your role in identifying change
    1. All personnel should feel empowered to raise issues when the MOC process is not being followed
    2. Work notifications and requests should be reviewed to ensure they have an MOC when required
    3. Is the operation you are about to perform described in the SOP or do you have to perform it in a different way? If a different way is needed then an MOC is required.
    4. All personnel should be aware that an MOC is required if the change is not a RIK (4)

How - Management

  1. Ensure that the appropriate personnel receive training.
    1. Training may have different levels, such as awareness training, MOC process and approval. 
    2. Roles in the MOC process should be identified and communicated.  (1)
  2. Ensure that the written process is properly followed
    1. Develop and monitor metrics to ensure MOCs are  followed
    2. Management review and auditing to ensure MOC’s requirements are being met.

How - Engineers and Designers

  1. Seek out and participate in training opportunities.
  2. Understand your role in identifying when an MOC is required.
  3. Decide whether large engineered or capital projects are controlled by the MOC process or a separate defined process
    1. The separate process must complement the MOC process and include all the basic requirements of an MOC process. Refer to “HOW ” general.

References and Supplemental Reading

  1. Supplemental Reading- CCPS book- Guidelines for Management of Change for Process Safety
  2.  Reference. CSB - US Ink/Sun Chemical Corporation Ink Dust Explosion and Flash Fires Final Report – 10/9/2012)  (Add link)
  3. Reference. CSB William Geismar Olefins Reboiler Rupture and Fire Geismar, Louisiana, Final report – October 2016) (Add link)
  4. Supplemental Reading- CCPS book - Guidelines for Risk Based Process Safety – MOC Chapter 15