Each week I get into some really deep discussion regarding Process Safety and it seems that many of these discussions involve changes and whether the change needs an MOC. So I thought it would be a good discussion point for us here to toss around. This scenario actually comes out of a 3-year audit I recently conducted and it involves PSM training and changes to e-mail addresses…
The facility was struggling with meeting their training needs and refresher due dates so they purchased a training management software. This type of software is very popular in managing training, but it does NOT do it all! The software runs using the individuals’ e-mail addresses to send out reminders and notices regarding training needs. The company’s IT department (at the headquarters – not at this plant) CHANGED the company’s format for e-mail addresses and thus all the internal e-mail addresses changed. There was a 3-month grace period where the old address would still be delivered but after the grace period e-mails would cease being delivered. No e-mails = this system is a boat anchor instead of a functioning electronic training management system.
We show up and begin finding a lot of training is past due and the EHS team is perplexed because the system had worked flawlessly for many years and no one was getting notifications of missed training. The facility management was so reliant on the system to send the e-mails of the missed training, failing grades, etc. that no one was going in and doing any analysis on the data which was abundantly available within the software (as we found during the audit). Basically, no e-mails regarding missed/failed training meant “all is well” to management. We merely asked for a “report” on a couple of PSM/RMP related topics and the EHS team ran the report with great confidence only to be crushed when the report showed 90%+
So the question is…
Was an MOC necessary to change the e-mail addresses since this change impacted the facility safety and PSM training management system?
We chose to tie a BMP type audit finding to the failure of the MOC process to catch this change which led to the failure of the PSM training refreshers. We issued an actual finding based on the missed training regardless of the excuse.
This is similar to the change I wrote about years ago where a facility was using CDs as their emergency back-up to access the SOPs and EAP/ERPs during power outages and network outages. The problem was IT had basically gotten rid of all the laptops with CD readers over the years. So when we asked an operator to print some of the documents on the CD to see if they were being updated when the SOP(s) were changed, we found that he/she could not find a laptop with a CD reader to even print the documents. And yes, the SOPs and EAP/ERP on the CD had not been updated for five years. But it was our inability to manage our technology that created the PSM deficiency. We use technology so much these days to help us manage all the EHS activities and when we become too reliant on this technology WITHOUT incorporating this technology into our overall management system we can fall flat on our face!