(53k) An Adaptable Approach to Management of Change

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In the world of Process Safety Management (PSM), some consider Process Safety Information (PSI) to be the keystone of the 14 Elements of Process Safety. However, in facilities with mature PSI programs, Management of Change (MOC) should be considered the key element that ensures the continued management of risks associated with a covered process. As a process undergoes equipment, procedural and even personnel changes, a robust MOC program is paramount to the success of the other 13 elements. Today facilities commonly utilize a standardized format for documenting changes (i.e., equipment, personnel, procedural, etc.). For relatively small administrative changes, this documentation can deter the initiator of the MOC. However, an “all-in-one” MOC form is not required and facilities can develop a MOC process that is designed for the various types of changes. In a categorized approach, if a standard operating procedure (SOP) for unloading chlorine at a facility requires a modification to the flow parameters, rather than completing a long (all-in-one) form, the initiator can use an MOC form specifically designed for documenting and communicating changes in SOPs. A tiered approach for this process would also be appropriate. For example, a Level I MOC is used for administrative changes, while Level III MOCs are used for large-scale equipment installations/modifications. With a tiered or categorized approach, the facility can use various types of MOC forms that are designed to document the specific types of changes. This approach allows employees to focus more on the critical information triggering the change, rather than sifting through pages of irrelevant information. This presentation will provide examples of how these programs are developed for various facilities. When properly implemented, a versatile approach to Management of Change will not only result in a strong PSM program, but also higher employee participation by removing unnecessary administrative obstacles.

-Brian Desrosiers, CSP, OHST

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