MANAGEMENT OF CHANGE MOC

Each plant is subject to changes involving machinery, equipment, instrumentation,

processes to increase productivity or correct hazardous situations.
In some cases there are temporary modifications such as connections, by-pass,
sometimes there are also organizational changes (staff reduction, elimination of
positions, mergers).
All these changes have the potential to create new workplace hazards, some of which
are not immediately recognizable.
Although some changes are more critical than others, any change should be analyzed
in order to identify the risks and dangers inherent in it.
To this end, each plant has a policy and a change management procedure (MOC),
which can provide the following benefits:
1. Less releases of dangerous substances
2. Less risky maintenance
3. Production due to minor business interruption tends to increase
4. Few accidents lead to fewer economic losses due to less frequent stops
5. Increases the reputation of the company towards customers, stakeholders,
employees, residents, government agencies, insurance companies, banks.
The process of managing the changes is:
Identification of the problem (it is essential that all staff is involved in the change
management process, a lack of education and experience does not mean that the
person cannot come up with useful suggestions)
Evaluation of the proposed modification
Basic Cause Analysis (Detailed analysis is required to identify the root causes of the
problem and areas where editing can be most effective)
Obtaining approval for modification (prior to modification, executives / managers must
formally approve it)
updating documentation (prior to implementation, all security documentation needs
updating, which means: staff training involved in modification, updating of operating
procedures, updating project designs, implementing corrective actions after HAZOP)
Notify everyone involved (before the implementation, all staff involved will be updated)
Implementation of the modification (the modification is implemented as planned)
monitoring the change (an impact analysis of the change in operations needs to be
done).
When should the edit procedure be used?:
Edit types:
In Kind
If the change corresponds to replacing a piece with another that specifies or functions
then in this case the Moc procedure is not required.
Critical change
A critical change can lead to an accident and therefore be handled with Moc.
Small / large change
Care must be taken to small changes that can lead to serious accident if neglected.
Emergency change
Every change of emergency should be revised with Moc to make sure there are no
unanticipated problems and make sure that the modification is documented and
monitored.
Temporary change
Usually they are done to keep the drive running while a piece of equipment is replaced.
A temporary change should always have a forward date. These changes must be
submitted to MOC.
Instrumentation change
Usually a modification of instrumentation systems requires MOC.
CHECKING LIST FOR MODIFIED MANAGEMENT
1. Is the amendment envisaging the use of different chemicals that may react with
others already present in the process?
2. Can the amendment include the production of by-products or other reactions or the
introduction of impurities with new substances?
3. Do you develop more warmth of reaction?
4. Is the modification for some appliances to work outside the approved process limits
for them?
5. Does the proposed amendment consider chemical compatibility with equipment
materials?
6. Are there any impacts on employee health?
7. Has the process for the change been subjected to a proper safety analysis by a
qualified person?
8. Is there a new equipment inspection to verify that they are in accordance with
specifications?
9. Have the drawings and procedures been updated to take account of the changes?
10. Have the right channels of communication been established for people affected by
the changes?
11. Have the verification of the modalities of the instrumentation been carried out?
Before authorizing a plant startup, the manager must conduct a pre-start up safety
review. While Osha Americana expects such an analysis for new plants or modified
before production starts. Typically, analysis Is led by a team of people in production,
maintenance, research and development and security.
An example checklist is provided:
PRE-START UP SAFETY REVIEW (PSSR) CHECKLIST
1. Have all the recommendations made in Haze been implemented?
2. Has a list of all critical safety equipment been prepared?
3. Are all critical security devices installed and running?
4. Has the operating manual been compiled and approved?
5. Have production procedures (SOPs) been documented including startup and
shutdown procedures?
6. Are production and maintenance personnel appropriately trained in operational and
safety procedures?
7. Does the procedure for managing the changes apply?
8. Have all instrumentation loops and DCS/ PLC systems been tested?
9. Is there a structure for people with emergency services?
10. Has the internal emergency plan been made and applied?
Bibliographic references: 1) guidelines for safe operation and maintenance CCPS
AIChE