Best practices for management
of change procedures
What is management of change?
The process safety management (PSM) standard requires employers to create and execute written management of change (MOC) procedures. MOC procedures help ensure the potential safety, health, and environmental impacts of changes are understood, managed, and controlled.
These changes include company changes related to processing chemicals, equipment, procedures, and facilities. A MOC must be performed unless the machinery or chemical is being replaced by the same machinery or chemical (replacement-in-kind).
Some organizational changes, such as mergers, acquisitions, reorganizations, workforce changes, or budget alternations, may affect PSM at the facility level and prompt a PSM MOC procedure. Examples include workforce changes such as increased or decreased workers, employee experience levels, or reliance on contractors that directly impact processes, procedures, and policy changes.
The MOC structure should include the use of a developed, written, and documented MOC review form. It should address the following before any change occurs:
1. The technical basis for the change
2. The impact of the change upon safety, health, and the environment
3. Changes required to any procedures
4. Time frame of the change
5. Authorization requirements for the change
Appropriate analytical techniques, including qualitative hazard evaluation methods, should be used to review the potential safety, health, and environmental impacts of a change. To learn more about the foundation of management of change check out our blog post: What is Management of Change?
When is a MOC necessary?
The PSM standard’s MOC acts to control company changes when the outcome could affect applicable processes. For example, a MOC procedure will be required if the company changes anything related to its process chemicals, technology, equipment, procedures, or facilities.
The MOC procedure would ensure that potential changes are appropriately managed and controlled to ensure safe operation for workers and the nearby community.
To determine if a MOC is required, the employer must conduct a MOC review if any changes directly affect process chemicals, technology, equipment, procedures, or facilities that are not a replacement-in-kind.
For example, suppose staffing gets cut in a specific production area. In that case, workers may not be able to continue implementing existing operating procedures due to the reduced number of workers to perform the required tasks.
Therefore, a MOC procedure must be carried out to manage the new change. In addition, the current operating procedure will need to be revised to reflect the reduced workforce level to ensure that operations remain safe under normal production and emergency conditions.
Budget modifications can have a related effect. For example, a significant decrease in a maintenance department’s budget may require an employer to modify its procedures for how often inspections and preventative maintenance occur on machinery. Less maintenance crew means fewer inspections.
Since this change requires machine procedures to be modified, a MOC procedure must be established and implemented to ensure the ongoing integrity of machinery to ensure the equipment is still receiving its manufacturer’s recommendations of inspections and maintenance requirements.
MOC items to consider
Additional items may need to be included in the MOC process or equipment change action plan. Depending on the potential change, the items listed below should be considered:
- The description and purpose of the change
- The technical reasoning for the change
- Safety, health, and environmental considerations
- Documentation of changes for operating procedures
- Preventative maintenance procedures
- Inspections and tests
- Pipe and instrument diagrams
- Electrical diagrams
- Pre-startup inspection
- The estimated duration of a temporary change
- An updated emergency contingency plan
- Approvals and authorization of management
Developing a list of areas, departments, and activities to which the MOC system applies and specific examples of changes and replacements-in-kind for each category ensures that the changes are properly managed and minimizes the possibility of the MOC system being inadvertently bypassed.
A designated approved person should authorize each MOC. Sometimes, the MOC reviewers satisfy the MOC approver function; sometimes, the approver is independent of the MOC reviewers.
MOC best practices
Updated or modified processes create new hazards. Therefore, employees need health and safety training on the new operating procedures or potential hazards anytime a MOC is performed.
In addition, all employees, including maintenance and contractor employees, need to fully understand the safety and health hazards and the controls of the chemicals and processes they operate.
In addition, the ‘worst-case scenarios’ should be updated when there is a process change to indicate the impact on nearby facilities and communities. The worst-case scenario assessment assumes that all current and backup safety systems have failed.
All potential scenarios must be considered and planned for, even those that are unrealistic. Sites must prepare, plan, and train employees for any potential situation that could affect workers and the community.
Even temporary changes can cause accidents. Temporary changes can still cause tragic situations, and therefore a MOC for short-term changes is required. These MOCs should include the approximate duration of the changes because sometimes, these changes become permanent.
Also, MOC procedures ensure that machinery and procedures are returned to their original design or condition after the temporary change.
Finally, the changes must be documented and reviewed to ensure that safety, health, and environmental considerations are integrated into the site’s operating procedures, machine specifications, and processes.
When the impact of the change is minor and the potential issues are fully understood, a checklist may be sufficient to understand the possible effects of the changes. For more major or significant changes, a hazard evaluation policy or procedure should be developed and implemented.
Everyone, including engineers, supervisors, managers, operators, and maintenance personnel, should be involved when developing new procedures for a process change. Operators that work on the equipment daily understand the health and safety hazards involved in the process the most. They are the best to help identify possible problems and effective controls.
The process change, emergency procedures, and environmental, health, and safety information need to be documented and stored in a location that is known and accessible to all employees involved.