Facilities subject to EPA’s Program 3 Risk Management Program (RMP) requirements or international standards such as Control of Major Accident Hazards (COMAH) in the UK must also have written MOC procedures.

The PSM standard is largely prescriptive about what details need to be in these procedures, stating they must include descriptions of the technical basis for the change, impact on safety and health, modifications to operating procedures, the time period necessary for the change, and appropriate authorizations. It also states that any employee who will be affected by the change must be informed and appropriately trained.

 According to OSHA, the common areas of non-compliance with MOC requirements include managing changes to equipment design and operating procedures, regular maintenance and repair to facilities, and documenting time limits for temporary changes. Let’s take a closer look at each of these, and how software makes managing change significantly easier.

Changes in equipment design

An operator must use MOC anytime the operational specifications of a piece of equipment are changed from the design indicated in the Process Safety Information (PSI) for your facility’s PSM plan. Design changes that alter chemicals used, or change operating parameters outside the ranges described in the PSI also trigger the need for MOC. The rationale here is that these changes can introduce new hazards, which then necessitate additional safeguards or controls.

Examples of changes in equipment design that would require use of MOC include the installation of a control valve bypass, changes to an alarm set point, or installation of a spill containment berm around a chemical storage tank.

Changes in operating procedures

Operators need to initiate MOC whenever operating procedures are changed for a PSM-covered process to ensure hazards associated with the procedural change are properly assessed and controlled. The MOC must also ensure training for all affected personnel takes place prior to the first start-up of the changed process.

Examples of changes in operating procedures requiring MOC include changing procedures for manual addition of a chemical to an injection tank, or changing procedures for operation of relief devices.

Changes in inspection & maintenance procedures

Whenever operators change inspection and maintenance procedures, including changes to preventative maintenance and equipment repair, they need to utilize MOC, since these changes can affect the risk levels of the associated process or equipment.

Examples of such changes include changing inspection intervals for piping circuits, changes in maintenance procedures following a change in process equipment, or changing the number of thickness measurement locations on a pipe.

Changes in facilities

Changes to the facility structures themselves are not always run through an MOC process, even though OSHA’s PSM standard requires it for these kinds of changes. This requirement is triggered whenever an existing structure is modified, or a newly installed facility structure is located within or near a PSM-covered process.

Potential examples include construction and installation of a shed structure near a hydrocracking or sweetening unit, or structural changes to a room located within a PSM-covered process unit.

Temporary changes

Of all of the uncontrolled changes that occur, temporary changes are pernicious and just as capable of causing accidents and incidents as planned changes. There’s nothing quite as permanent as temporary change, especially as it relates to the potential damage that can result from temporary changes that are not properly planned.

For this reason, OSHA mandates that temporary changes to PSM-covered processes – which are usually initiated while permanent changes are being made – must be properly assessed through the MOC process. MOC should address the allowable time the temporary changes can exist before the permanent changes are finalized, as along with procedures for confirming the removal of the temporary changes, whether because of finalization of permanent changes or reversion to the original conditions.

Examples of temporary changes that require MOC include using temporary supports during installation of a new vessel or piping circuit, or using a shed or break area as a temporary control room during repair of the main control room.

Best practices and technology resources

Ideally, MOC should afford you a transparent, accessible and verifiable change request system, ensuring that no changes be made without the identification of risks and controls, or without appropriate authorization. In fact, an effective MOC process is so useful that its benefits outside of regulatory compliance with PSM and other standards are being more widely recognized, with safety professionals increasingly using MOC to address a wider range of planned changes that may have safety or environmental consequences.

 Unfortunately, the use of hard copy review forms or other homegrown methods in MOC processes significantly slows it down, and can result in catastrophic errors. 

 Whether your specific drivers for adopting or improving Management of Change are regulatory, organizational continuous improvement, or strictly focused on increasing efficiency in your existing MOC program, implementing the right software tool will significantly increase the likelihood of achieving your goals. Ultimately, MOC is about visibility, collaboration and workflow control, and all these areas are uniquely suited to software-based solutions.