Management of Change, or MOC, has been a regulatory requirement for more than twenty years, but companies are still struggling with it. The struggle hasn't stopped regulatory agencies from expanding the scope of requirements. Organizational change is hotly debated because Process Safety Management (PSM) does not expressly require it to be part of the MOC process. Despite pushback from industry, the Occupational Safety and Health Administration (OSHA) now requires MOC through written interpretations. Recent developments in the Gulf of Mexico now require the oil and gas industry to address organizational change and workforce competency as part of MOC. While there are some differences in the onshore and offshore regulations, the basics for MOC are the same:
Changes must be properly designed, specified, approved, implemented, and the associated documentation updated.
MOC is typically implemented as a risk assessment tool from a process safety compliance perspective. However, it touches nearly every business process and employee at an operating facility.
Management of Change is perhaps the most difficult business process to implement at a facility.
In advanced operating cultures, MOC extends beyond compliance to become an effectiveness and efficiency solution with a significant positive impact on profitability. Done well, MOC can drive down operating costs; but all too often, MOC is vetted out in isolation without full business process integration and then cannot deliver the full potential for business benefits.
Operational Sustainability, LLC® assists clients with Management of Change by developing business processes, standards, policies, procedures, and field guides. The Operational Sustainability OESuite™ software effectively addresses all aspects of change from an integrated perspective, including facility, technology, and personnel changes. Our Management of Change software comes with pre-configured MOC templates, reports, and dashboards.
A robust MOC solution incorporates a Pre-Startup Safety Review (PSSR) process step. The PSSR is meant to assure that all punch list items are complete, procedures are updated, and training on the change is conducted prior to startup. PSSR is usually facilitated by a series of checklists that help determine that construction is in accordance with design specs and more simply that bolts are tight, safety showers functional, alarms audible, and a host of other issues all based on the scope of the change. A PSSR can be a standalone activity (i.e., Ad hoc Maintenance).
MOC regulates direct modifications to refining and chemical processes as well as changes that have indirect impact such as personnel changes. It is designed to require change review and approval in order to prevent process safety incidents. Performing MOC well delivers additional payback including fewer unplanned outages since equipment uptime will be increased and startups decreased.