Successful management of change (MOC) programs identify potential process hazards.
Managing changes to processes is one element under the managing risk foundational block of the risk-based process safety (RBPS) approach to process safety management (PSM) developed by the Center for Chemical Process Safety (CCPS). Management of change (MOC) programs help ensure that changes to a process do not inadvertently introduce new hazards or unknowingly increase risks associated with existing hazards (1).
The key to a successful MOC program is to identify potential process hazards so they can be managed safely. A typical MOC process consists of a few key steps: recognizing what needs to be changed, evaluating the hazards, deciding whether or not to move forward with the change, implementing the change, and conducting appropriate follow-up measures to control the risks associated with the change. As part of the MOC process, facilities complete a process hazard analysis (PHA). Some of the commonly used PHA techniques are what-if analyses and hazard and operability (HAZOP) studies. These methods require:
- an understanding of the relevant process hazards
- identification of process deviations and potential adverse consequences
- recommendations for eliminating the hazard or implementing preventive and/or mitigative safeguards, based on the risk assessment.
This article highlights process hazards that are commonly missed while managing changes and provides lessons learned from past incidents to overcome these deficiencies. It discusses gaps in process safety competencies of the personnel managing the changes and the need for compliance with standards — both of which are elements of the CCPS RBPS management system — and provides lessons learned to overcome these deficiencies...
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