The Importance of Management of Change (MOC) in Preventing Chemical Accidents
It seems almost every few months there’s another story in the news about a major chemical accident somewhere in the United States. On June 21, 2019 a major explosion at a petroleum refinery just outside of downtown Philadelphia, PA injured five workers and endangered thousands of nearby Philadelphia residents. The damage was so severe that the facility was ultimately forced to close its doors and lay off hundreds of its employees, and the full health and environmental impact of the accident has yet to be determined.
The sad fact is that major chemical-related accidents like these are far more common than you’d think. A 2016 EPA review of chemical incidents found that over 2,200 chemical-related accidents had occurred between 2004 and 2013, killing 59 people and injuring over 17,000. That’s an average of about 150 fires, explosions and other hazardous releases each year.
Chemical Process Safety
The U.S. Chemical Safety Board (CSB) is responsible for investigating major chemical-related accidents, and developing recommendations for both businesses and regulators to improve chemical process safety. Of the more than 100 investigations performed by CSB since 1998, the vast majority of accidents have one thing in common — they were caused by deficiencies in chemical process safety.
Both OSHA and EPA enforce regulations designed to ensure the safety of hazardous chemical processes — OSHA with its Process Safety Management (PSM) standard, and EPA with the Risk Management Plan (RMP) rule. As we can see in this comparison chart, these regulations contain a number of overlapping requirements for facilities that process toxic and highly hazardous chemicals. These include the need to perform and document formal management of change (MOC) activities for operational or organizational changes related to a covered process, and pre-startup safety reviews (PSSR) prior to implementation of covered process changes.
MOC is a systematic method for ensuring that safety, health and environmental risks are identified and controlled, both before and during implementation of changes to facilities, personnel, policies or operations involving chemical processes. The MOC requirements listed in the OSHA PSM standard and EPA’s RMP rule are essentially identical, with the RMP requirements stating:
(a) The owner or operator shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process.
(b) The procedures shall assure that the following considerations are addressed prior to any change:
- The technical basis for the proposed change;
- Impact of change on safety and health;
- Modifications to operating procedures;
- Necessary time period for the change; and,
- Authorization requirements for the proposed change.
(c) Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process.
(d) If a change covered by this paragraph results in a change in the process safety information required by §68.65 of this part, such information shall be updated accordingly.
(e) If a change covered by this paragraph results in a change in the operating procedures or practices required by §68.69, such procedures or practices shall be updated accordingly.
Put simply, compliance with PSM and RMP regulations requires covered facilities to establish a system to not only document the required change-related information, but to also notify affected employees of the status of changes at one or more stages of implementation, and verify that affected employees have received training in the those changes and how they impact the performance of job tasks.
Pre-Startup Safety Review (PSSR)
PSM and RMP regulations also establish requirements for covered facilities to perform pre-startup safety reviews prior to process changes. Both PSM and RMP regulations specify that:
(a) The owner or operator shall perform a pre-startup safety review […] when the modification is significant enough to require a change in the process safety information.
(b) The pre-startup safety review shall confirm that prior to the introduction of regulated substances to a process:
- Construction and equipment are in accordance with design specifications;
- Safety, operating, maintenance, and emergency procedures are in place and are adequate;
- A process hazard analysis has been performed and recommendations have been resolved or implemented before startup, and modified facilities meet the management of change requirements [listed in each respective regulation]; and,
- Training of each employee involved in operating a process has been completed.
In a nutshell, pre-startup safety review (PSSR) requirements mean that covered facilities must implement system(s) to verify and document that critical safety countermeasures and hazard controls are in place, that all initial and residual risks have been identified and addressed, and that affected employees possess the knowledge and skills to perform job tasks safely during and after process changes. Like MOC activities, PSSR systems and the reviews themselves must also be documented for the purpose of demonstrating compliance with PSM and RMP requirements.
Industry-Leading MOC Capabilities are Just the Beginning!
If your facility is subject to chemical process safety requirements, you know that performing and documenting all of your MOC and PSSR activities for each covered process can be a difficult, time-consuming challenge. This is particularly true for large petrochemical manufacturers and similar facilities that often have dozens of processes running simultaneously, or where changes to chemical processes occur on a frequent basis.
VelocityEHS Management of Change is a comprehensive cloud software solution that helps business of all sizes across a wide range of industries comply with PSM, RMP and other chemical process safety standards like the UK ‘s HSE COMAH regulations. You can easily coordinate workflows and approval processes, perform and document PHAs, identify and analyze risks, schedule and perform both PSSR and post-startup safety reviews, and automatically generate email notifications for assigned personnel at each step throughout the change process to keep everyone on the same page. It’s an all-in-one change management platform that has been ranked as the industry’s best MOC solution by leading third party EHS software analyst firm, Verdantix.
But management of change is only one part of compliance with PSM and RMP requirements. Covered facilities also need to have systems in place to manage everything from incident investigations, hazard communication, training, and emergency planning and response. That’s why VelocityEHS offers powerful, yet easy-to-use software solutions to help you manage virtually every aspect of chemical process safety.