In industrial settings, changes occur every day.
Manufacturing processes evolve amidst a constant wave of new knowledge, technologies, and equipment. This evolution is triggered by a myriad of circumstances, whether they are equipment upgrades, process innovations from employees, or even unexpected scenarios, such as an equipment failure.
Each change has cascading effects that affect a plant’s ability to maintain a safe and effective environment.
This web of ripple effects around a change is corralled through the management of change process, or “MOC.”
So, what exactly is an MOC?
MOCs are just as they sound; a process to manage changes.
Successful MOCs require a disciplined and consistent approach to document changes, evaluate and identify hazard mitigation options and controls, approvals, reduce risks, and ensure successful implementation.
How does it work?
When changes occur, the MOC process guides a team knowledgeable of the change through defining the scope of change, evaluating and mitigating potential risks and hazards associated with the change, and updating associated process safety information.
MOC interface, approvals, and templates may look different for every company, but all hold the same core intent, covering questions like...
How will this change impact health, safety, and the environment?
How will this change affect associated equipment and process?
Will this change introduce any inadvertent risks or hazards?
Have we designed the change thoroughly?
How will it affect others (and how will we let them know)?
Have we identified all the process safety information and other documentation requiring updates?
In addition to evaluating risks, the MOC team accomplishes other important objectives, including:
Verify the change meets the team’s needs
Evaluate alternative solutions
Confirm the change is technically well-designed
Informs (and sometimes trains) affected personnel
Identify and update process safety information and other documentation
Establish timelines and deadlines for all required activities, including temporary changes!
Acquire approvals at certain gateways throughout the process
Why are they important?
While this may seem like a lot of work for a minor change, there are good reasons for it!
MOCs keep employees safe.
Unmitigated risks can have dangerous consequences. Historically, there are numerous incidents associated with improper change management. Unfortunately, some have been fatal such as Puget Sound Refinery in 1998, which stemmed from a process change, and Flixborough originating from an equipment modification.
MOCs are necessary for compliance.
Because of incidents like those above, OSHA enacted a process safety management standard (PSM) for facilities that manage “highly hazardous chemicals” (listed here by OSHA, CFR 1910.119 Appendix A). The EPA has also included provisions for chemical accident prevention facilities that use certain hazardous substances, called the Risk Management Plan rule. This rule contains similar management of change requirements. While not all industrial manufacturing facilities meet these criteria, internal risk & compliance teams may voluntarily enforce these standards as best practice.
MOCs allow everyone to do their job better.
A well-performed MOC will ensure the change is well-designed, lengthens asset reliability, and minimizes harmful personnel and environmental incidents. Engineers, operators, and supervisors all rely on up-to-date process safety information to complete initiatives around the plant. Inconsistencies from poor MOCs create extra work for fellow engineers & operators at best. At worse, it compromises their safety.
So, while MOCs might sometimes be met with an eye roll or a groan, they should be welcomed and embraced as a critical part of plant safety and productivity!