The Constant Danger of Not Following Proper Process Safety Protocol

While many operating companies have reshaped their Management of Change (MOC) programs based on past experiences and prevalent best practices, there are those still struggling to address issues affecting overall program objectives and effectiveness. Our experiences in the implementation of MOC processes and systems have led us to identify some of the most common pitfalls.

MOC Implementation Issues

Do any of these sound familiar?

• Inadequate definition of a change ― What is replacement in kind?
• Resolution of temporary changes ― Do you extend the duration of the change, return the process to original condition, or make the change permanent?
• Managing emergency changes ― How do you ensure that all requirements of normal changes are satisfied?
• Procedural changes ― Do they require a pre-startup safety review?
• Tracking/closure of action items ― How do you verify that action items have been completed and meet intent of the recommendation?
• Communication of the change ― How do you accomplish this and maintain adequate documentation?
• Pre-startup safety review ― How do you decide when one is needed?
• Updating process safety information ― How do you manage updating to ensure MOCs are closed out in a timely manner?
• Process Hazard Analysis (PHA) issues ― How to decide when one is needed? How do you integrate MOC information with a current PHA?

Gain Important Insights

One of the Process Safety Management (PSM) concepts that so many have struggled with is Management of Change (MOC). It seems so simple on the surface, but it has resulted in serious incidents. Stay vigilant by reading A Tale of Two MOCs by Pamela Nelson and Lisa Ruth, for lessons learned resulting from MOC failures.

Using familiar character types and forms, these fairytales illustrate why the change was not recognized, the hazards of uncontrolled changes, and the importance of MOC in the prevention of process safety incidents. The story, while populated with make believe characters, illustrates the real-life hazards that exist when uncontrolled changes are made.

Unfortunately, there are those who view management of change as a tedious paperwork exercise. Others do not recognize that changes have the potential to introduce hazards. A lack of recognition of the importance of Management of Change in the prevention of process safety incidents could ruin the existence of a happily ever after.

Read the full article A Tale of Two MOCs published by the Chemical Engineer Magazine.

We Can Help

ioMosaic has the training, software, and service solutions to help resolve any Management of Change (MOC) issues. You can count on us for guidance that not only satisfies regulatory requirements but delivers peace of mind to you. Contact us at 1.844.ioMosaic or send us a note via our online form. We would love to hear from you.