Course Material

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Overview of Process Safety

Compliance with Standards
Process Hazard Analysis
Standard Operating Procedures
Safe Work Procedures
Mechanical Integrity
Management of Change
Auditing Process Safety Systems
Emergency Response Procedures

Process Safety
Management for
Biofuels

7. Management of Change
29 CFR 1910.119 (l)
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.

Flixborough Reactor Series

Bellows at Flixborough

Of

Management of Change

1. System Design

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

Management of Change
Types of MOC

process chemicals,
technology,
equipment,
procedures
facilities

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
System Design

1. Written MOC procedures

2. MOC owner
3. Defined scope
4. Defined roles and responsibilities

Management of Change
System Design

5. Management of Change log

6. Management of Change form
7. Periodic monitoring (field checks)
8. Auditing

Management of Change
Training

2. The
Management of Change
(MOC) Process

MOC

Replacement in Kind

Actuated butterfly
valves

Butterfly valve

Ball valve

Gate valve

Management of Change
Training on the Change

Management of Change
MOC FORM

1. Technical basis
2. Impact on safety and health
3. Modifications to operating procedures
4. Necessary time period for the change
5. Authorizations

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 Change
5. Authorizations

DEFINING ROLES AND

RESPONSIBILITIES

DEFINING ROLES AND

RESPONSIBILITIES
Change
Originators

ROLES AND RESPONSIBILITIES

Reviewers

ROLES AND RESPONSIBILITIES

MOC Coordinator

ROLES AND RESPONSIBILITIES

PSM Manager

ROLES AND RESPONSIBILITIES

Employees

ROLES AND RESPONSIBILITIES

Senior Management

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 specifications
8. DCS programming change requests
9. Process experiments or tests conducted in the
manufacturing plant.
10. Contractor service agreements

Guiding Principles for

Implementation
1. Keep it simple
2. Obtain acceptance
3. Field test the system
4. Provide adequate training

3. Maintaining an effective
Management of Change
(MOC) Process

Maintaining an MOC
System
1. Monitor effectiveness
2. Audit
3. Demonstrate commitment

Effectiveness of MOC System

Key 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 System

Auditing
1. Documentation completed
2. Training conducted
3. Procedures reviewed for updating
4. Pre-Startup Safety Reviews

Management of Change

Pre-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.

Definitions
Trigger Event
Any change being made to an existing process,
or
any new facility being added to an existing process
or facility,
or
any other activity a facility designates as needing a
pre-startup safety review.

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

Best Practices PSSR

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.

Compiling and Using a

PSSR Checklist
kl i s
c
e
Ch

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.
2.
3.
4.
5.
6.
7.
8.
9.

Overview of Process Safety

Compliance with standards
Process Hazard Analysis
Standard Operating Procedures
Safe Work Procedures
Mechanical Integrity
Management of Change
Auditing Process Safety systems
Emergency response procedures