Course Material

1. Overview of Process Safety

2. Compliance with Standards
3. Process Hazard Analysis
4. Standard Operating Procedures
5. Safe Work Procedures
6. Mechanical Integrity
7. Management of Change
8. Auditing Process Safety Systems
9. 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

t
ecklis
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. Overview of Process Safety
2. Compliance with standards
3. Process Hazard Analysis
4. Standard Operating Procedures
5. Safe Work Procedures
6. Mechanical Integrity
7. Management of Change
8. Auditing Process Safety systems
9. Emergency response procedures