Course Material

Course Material1. Overview of Process Safety2. Compliance with Standards3. Process Hazard Analysis4. Standard Operating Procedures5. Safe Work Procedures6. Mechanical Integrity7. Management of Change8. Auditing Process Safety Systems9. Emergency Response Procedures

7. Management of Change

Process Safety Management for

Biofuels

This material was produced under grant SH-19479-09-60-F-36 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.

29 CFR 1910.119 (l)

Flixborough Reactor Series

Bellows at Flixborough

Of

Management of Change

1. System Design

Management of change (MOC) A management system for ensuring that changes to processes are properly analyzed, documented, and communicated to affected personnel.

Definitions

process chemicals, technology, equipment, procedures

facilities

Management of Change Types of MOC

Process Safety Information

1910.119(l)(4)If a change covered by this paragraph results in a change in the process safety information required by paragraph (d) of this section, such information shall be updated accordingly.

Management of Change

1. Written MOC procedures2. MOC “owner”3. Defined scope 4. Defined roles and responsibilities

System Design

Management of Change

5. Management of Change log

6. Management of Change form

7. Periodic monitoring (field checks)

8. Auditing

System Design

Management of Change Training

2. The Management of Change

(MOC) Process

MOC

Replacement in Kind

Gate valveButterfly valve Ball valve

Actuated butterfly valves

Management of Change

Training on the Change

Management of Change

1. Technical basis

2. Impact on safety and health

3. Modifications to operating procedures

4. Necessary time period for the change

5. Authorizations

MOC FORM

1. Technical Basis for Change

What?How?Why?

Where?When?

2. Impact on Safety & Health

3. Modifications to Operating Procedures

4. Necessary time period for the change

MOC

Management of Change5. Authorizations

DEFINING ROLES AND RESPONSIBILITIES

Change

Originators

DEFINING ROLES AND RESPONSIBILITIES

ROLES AND RESPONSIBILITIES

Reviewers

MOC Coordinator

ROLES AND RESPONSIBILITIES

ROLES AND RESPONSIBILITIES

PSM Manager

ROLES AND RESPONSIBILITIES

Employees

Senior Management

ROLES AND RESPONSIBILITIES

Changes to cover under MOC

1. Capital improvement projects

2. Maintenance work orders

3. Instrument change requests

4. Spare parts control,

warehousing, and distribution

5. Engineering change requests

Changes to cover under MOC

6. Research and development (R&D) process change recommendations

7. Company specifications8. DCS programming change requests9. Process experiments or tests conducted in the

manufacturing plant.10. Contractor service agreements

1. Keep it simple

2. Obtain acceptance

3. Field test the system

4. Provide adequate training

Guiding Principles for Implementation

3. Maintaining an effective Management of Change

(MOC) Process

1. Monitor effectiveness

2. Audit

3. Demonstrate commitment

Maintaining an MOC System

Effectiveness of MOC SystemKey Performance Indicators

1.The number of MOCs performed each month.2.The monthly percentage of work requests that are

classified as a change.3.The percentage of emergency MOCs.4.The average backlog of MOCs.5.The average calendar time from MOC origination

to MOC authorization.

Effectiveness of MOC SystemAuditing

1. Documentation completed2. Training conducted3. Procedures reviewed for updating4. Pre-Startup Safety Reviews

Management of ChangePre-Startup Safety Reviews

Pre-Startup Safety Review

The term pre-startup safety review (PSSR) means a final check prior

to initiating the use of process equipment.

PSSR

It is applying a systematic method to confirm that the startup team and

process equipment are prepared for startup.

Any change being made to an existing process,or

any new facility being added to an existing process or facility,

orany other activity a facility designates as needing a

pre-startup safety review.

DefinitionsTrigger Event

Non-change Trigger Event

When Should a PSSR be Performed

1. Capital project approved

2. Changes to Operating Facilities occur

3. Temporary Changes (Flixborough)

4. Restart of an idled process

1. Regularly evaluating industry process safety related incident reports and how PSSR was potentially involved in the situation.

Best Practices – PSSR

2. Using electronic databases for capturing past PSSR documentation.

Best Practices - PSSR

3. Performing PSSRs on selected critical maintenance activities.

Best Practices - PSSR

4. Involving many different workers in the PSSR process.

Best Practices - PSSR

5. Selecting a PSSR team leader who is somewhat removed from the specific project involving the change.

Best Practices - PSSR

6. Showing open management support for the importance of PSSR.

Best Practices - PSSR

Compiling and Using a PSSR Checklist

Checklist

Compiling and Using a PSSR Checklist

The role of the PSSR program is to provide a second layer of protection around the management of change element.

Compiling and Using a PSSR Checklist

Depending upon the specific processes, materials, intermediates, and products involved, the PSSR checklist questions should be customized to match the facility.

Remaining Course Material

1. Overview of Process Safety2. Compliance with standards3. Process Hazard Analysis4. Standard Operating Procedures5. Safe Work Procedures6. Mechanical Integrity7. Management of Change8. Auditing Process Safety systems9. Emergency response procedures