Keys to Avoid Making a Dog's Breakfast out of Your MOC System

When thinking about MOCs on a case by case basis it is easy to forget the overall role of a change management system.  Think of MOC as a security checkpoint that protect the current process safety design and helps validate the adequacy of the current design for the change(s) proposed. Just as important, this means the MOC system also needs to ensure that any impacts of the change to other PSM systems’ implementation are identified and addressed.  This requirement makes an MOC system inherently complex.  Though extra care is needed to design some aspects of MOC for ease of use and efficiency across the organization, if key components are not addressed, an MOC system can quickly become a dog’s breakfast.  A mature robust MOC system must address many aspects of change, specific circumstances and nuances that if unchecked can weaken an organization’s perspectives on MOC and override the discipline to carry out day to day change management. This paper will discuss how a weak MOC system affects implementation of other process safety management systems. Therefore, an MOC system must be designed to identify and address how the proposed change can affect implementation of other PSM systems.

This will be accomplished by first discussing the relationship between PSI and MOC and how together these elements influence the implementation of all process safety elements. Examples will show how even simple changes can require revising many documents that support day-to-day implementation of many PSM elements.  If these documents are not identified for revisions to reflect the change, then the MOC security checkpoint fails.  The paper will also discuss the MOC system components and work flow necessary to help ensure these documents are identified and properly closed along with other MOC system features necessary for an efficient, compliant and effective MOC system.  This will be illustrated based on the recent eMOC system rollout at Irving Oil, New Brunswick, Canada. Also examples of common MOC system weaknesses discovered throughout audits across small and large sized facilities and a variety of chemical processes will be presented, such as the previously mentioned PSI and other document updates, and also management of temporary changes, quality of risk reviews and the MOC process work flow.