Management of Change (MOC): Strategies for Compliance
For operations involving hazardous processes, change management can be a matter of life and death. Operational failures resulting from insufficiently planned changes can cause catastrophic events such as explosions or chemical releases that endanger human lives, and the environment. That is why OSHA developed the Process Safety Management (PSM) of Highly Hazardous Chemicals Standard, which affects processes using high risk chemicals, and includes regulatory requirements for these operations to have written MOC procedures in place. Facilities subject to EPA’s Program 3 Risk Management Program (RMP) requirements or international standards such as Control of Major Accident Hazards (COMAH) in the UK must also have written MOC procedures. However, the very nature of facilities that are subject to MOC requirements — including high risk and operational complexity — also make change more challenging to manage.
Managing change can be easier with the right guidance and the right tools. As a prime example, let’s take a look at the required components of MOC as outlined in the PSM standard, along with some of the ways technology can help ensure an effective and compliant system.
What Is Required?
The MOC section of the PSM standard requires the employer to develop and implement written procedures to manage changes to process chemicals, technology, equipment, procedures, or to facilities that perform a specific covered process. The standard is prescriptive about what details need to be in these procedures. They must include descriptions of the technical basis for the change, impact on safety and health, modifications to operating procedures, the time period necessary for the change, and appropriate authorizations. The MOC section of the standard also states that any employee who will be affected by the change must be informed and appropriately trained.
According to OSHA, common areas of non-compliance with MOC requirements include managing changes to equipment design and operating procedures, regular maintenance and repair to facilities, and documenting time limits for temporary changes.
Changes in Equipment Design
Any time that the operational specifications of a piece of equipment are changed from the design indicated in the Process Safety Information (PSI) for a facility’s PSM plan, an operator must use MOC. Design changes that alter chemicals used, or change operating parameters outside the ranges described in the PSI also trigger the need for MOC. The rationale behind this requirement is that any changes of this nature can introduce new hazards, which then necessitate additional safeguards or controls. Examples of changes in equipment design that would require use of MOC include installation of a control valve bypass, changes to an alarm set point, or installation of a spill containment berm around a chemical storage tank.
Changes in Operating Procedures
Operators need to initiate MOC whenever operating procedures are changed for a PSM-covered process, in order to ensure that hazards associated with the procedural change are properly assessed and controlled. The MOC must ensure training for all affected personnel takes place prior to the first start-up of the changed process. Examples of changes in operating procedures requiring MOC include changing procedures for manual addition of a chemical to an injection tank, or changing procedures for operation of relief devices.
Changes in Inspection and Test and Maintenance Procedures
Whenever operators change inspection and maintenance procedures, including changes to preventative maintenance and equipment repair, they need to utilize MOC, since these changes can affect the risk levels of the associated process or equipment. Examples of such changes include changing inspection intervals for piping circuits, changes in maintenance procedures following a change in process equipment, or changing the number of thickness measurement locations on a pipe.
Changes in Facilities
Changes to the facility structures themselves are not always run through an MOC process, even though OSHA’s PSM standard requires use of MOC for these kinds of changes. This requirement is triggered whenever an existing structure is modified, or a newly installed facility structure will be located within or near a PSM-covered process. Potential examples include construction and installation of a shed structure near a hydrocracking or sweetening unit, or structural changes to a room located within a PSM-covered process unit.
The economist Milton Friedman was fond of quipping that “nothing is so permanent as a temporary government program.” Likewise, there’s nothing quite as permanent as temporary change, especially as it relates to the potential damage that can result from temporary changes that are not properly planned. For this reason, OSHA mandates that temporary changes to PSM-covered processes, which usually are initiated while permanent changes are being made, must be properly assessed through the MOC process. MOC should address the allowable time the temporary changes can exist before the permanent changes are finalized, as well as procedures for confirming the removal of the temporary changes, whether because of finalization of permanent changes or reversion to the original conditions. Examples of temporary changes that require MOC include using temporary supports during installation of a new vessel or piping circuit, or using a shed or break area as a temporary control room during repair of the main control room.
Best Practices and Technology Resources
Ideally, MOC should afford you a transparent, accessible and verifiable change request system, ensuring that no changes can be made without identification of risks and controls, or without appropriate authorization. The process is so useful that its benefits outside of regulatory compliance with PSM and other standards are now widely recognized, and facility managers increasingly see the wisdom in using MOC to address a wide range of planned changes that may have safety or environmental consequences. However, a traditional MOC process involving hard copies of review forms can quickly become labor intensive, and facilities with a high demand for managing change may need greater internal resources, in terms of both personnel and funding, to handle the workload.
Fortunately, technology solutions are now available to help streamline MOC tasks, making compliance easier and putting highly effective change management capabilities within reach of both facilities with regulatory MOC requirements, as well as those who simply wish to adopt it as a best practice. Multi-tenant cloud solutions are particularly valuable for management of complex facilities or multiple facilities who have extensive change management needs. These solutions enable a person responsible for implementing MOC activities to maintain a complete record of changes and approvals in one central system that is accessible anywhere, at any time. They also allow users to create configurable workflows with checklists for designers, reviewers and approvers, and easily assign approvals to the appropriate personnel. Additionally, the best MOC solutions even allow users to issue and modify change requests directly from their mobile devices.
Let VelocityEHS Help!
Ranked as the industry’s best Management of Change system by third-party EHS software analyst firm Verdantix, the VelocityEHS MOC solution makes it easy for you to ensure compliance with the MOC requirements of OSHA’s PSM standard and other similar regulations, while simplifying and streamlining all aspects of organizational change — from evaluating and documenting the potential risks of changes and change alternatives, to coordinating workflows and approvals, to tracking pre- and post-implementation action items. In addition, because our solution is designed as a multi-tenant SaaS platform, you get all the added system accessibility and security benefits of the cloud. Visit our website at www.EHS.com to learn more about how we can help your business not just manage change, but master it.