6) Always Update Documents that are Related to the MOC | AIChE

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6) Always Update Documents that are Related to the MOC

Last updated September 2, 2020

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6) Always update documents that are impacted by and relevant to the MOC

Why

  1. Process Knowledge  (Process Safety Information) and other impacted documents must be complete, correct and up to date:
    1. Hazard Identification and Risk Analysis and other Safety reviews are based on having accurate information. (1)
    2. Plant operations are based on having correct information (2)
    3. Up to date documents ensure that decisions are made based on accurate information. (3)
    4. Up to date documents ensure that Process Safety Management activities are executed based on accurate information

  2. Incidents:

    1. On February 19, 1999 an explosion occurred in a distillation system killing 5 people and injuring 14 people at Concept Sciences, Inc. facility near Allentown, Pennsylvania. Employees were distilling the first commercial batch of an aqueous solution of Hydroxylamine. Records indicate the Hydroxylamine concentration reached 86 wt %. It was known in the pilot-plant operation that high concentrations in excess of 70 wt % of Hydroxylamine were explosive. That vital information was not adequately shared with the plant. (4)

How - General

  1. Define a documented process for updating information impacted by the MOC to include:
    1. new information pertaining to the chemicals ,
    2. new information pertaining to the technology of the process
    3. new information pertaining to the process equipment
    4. new information pertaining to facilities, utilities or infrastructure.
    5. all remaining policies, procedures, or other written practices
  2. Define primary persons responsible or subject matter experts for each category of Information to ensure new or revised data is input and meets requirements.

How - Operators and Maintenance

  1. Learn what information is included in PSI. (3)
  2. Learn what other information is relevant in policies, practices and procedures.
  3. Verify that information impacted by the change is accurate. For example, ensure the P&ID matches the field conditions, ensure Operating Procedures properly describe tasks, ensure equipment information is up to date with actual field conditions. (5)
  4. When any questions on the accuracy or completeness of information arise, elevate the concern to supervision. (5)

How - Management

  1. Ensure that the roles for updating documentation are formally assigned in an appropriate procedure.​​​​​​
  2. Ensure that documents are being updated through self-audit activities. Many companies use tracking software / systems for this activity. (6)
  3. Define and monitor metrics to track open action items associated with information updates. It is often the case that information update action items can remain open for long durations. (7)
  4. Set expectations for timely closure of action items to update information. Timely in this case to be measured in months (not years). (5)
  5. Define a method to periodically self-audit the information for accuracy and completeness. This is an audit of the quality of the updates. (6)

How - Engineers and Designers

  1. Understand your role in updating documentation to include chemical, technology and equipment information. It is usually the case that engineers and designers are responsible to ensure information is updated following an MOC. (3)
  2. Provide training to operators and mechanics on content and changes to information as appropriate. In some situations, only input to the training materials would be provided. (See MOC Golden Rule #7)

References and Supplemental Reading

  1. Supplemental Reading, - Guidelines for Risk Based Process Safety, Chapter 9, Hazard Analysis and Risk Analysis​​
  2. Supplemental Reading, - Guidelines for Risk Based Process Safety, Chapter 10, Operating Procedures
  3. Supplemental Reading, - Guidelines for Risk Based Process Safety, Chapter 8, Process Knowledge Management
  4. Reference- Chemical Safety Board – Concept Sciences Explosion Final Report – March 2002 (add link)
  5. Supplemental Reading, - Guidelines for Risk Based Process Safety, Chapter 3, Process Safety Culture
  6. Supplemental Reading, - Guidelines for Risk Based Process Safety, Chapter 22, Management Review
  7. Supplemental Reading, - Guidelines for Risk Based Process Safety, Chapter 20, Measurements and Metrics

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