How much do you utilize your Management of Change (MOC) tool? Usually, when the acronym MOC is even whispered, many people begin to roll their eyes, sigh, and in some cases become physically angry. This is one of the mysteries I hope to solve before my retirement – why would anyone dislike a tool that is provided to merely aid in managing “changes”. Why the hostility toward a tool? To start with, unfortunately, most do not view the MOC process as a “tool” but rather a series of paperwork burdens that one must navigate to “get their job(s) done”. This article will demonstrate just how far we should be utilizing our MOC tool to manage changes, specifically changes to our safe work practices such as changing to a new brand and model of direct-reading instrument(s).
Let me start with mentioning the specific safe work practices that OSHA and EPA mention in their process safety standards:
1910.119(f)(4)
The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.
§68.69(d)
The owner or operator shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a stationary source by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.
Next we look at the MOC minimum requirements from these standards:
1910.119(l)(1)
The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
§68.75 Management of change.
(a) The owner or operator shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process.
As I have stated before, it is my belief that a mature safety management system will not parse words like “procedures”, “policies”, “practices”, and “programs”. After all we as a profession use these terms in many different ways; often times when the two safety professionals are actually talking about the same document, one calls it a “procedure” and the other calls it a “program”. So when OSHA/EPA uses the word “procedures” in their MOC application requirements and then uses the word “practices” in their safe work practices requirements I do not see any difference in these terms when putting my MOC tool to use.
Here is an example of how a MOC could have saved a lot of time, $ and hassle…
A petrochemical facility has an extensive PRCS entry program and averages 5 entry permits per week, in other words, they are well experienced in PRCS entry. In 2018 the safety team decided it was time to upgrade an aging fleet of direct-reading monitors and in doing so they obtained bids from three major providers of these devices. One of the brands would be from the current brand in use and the other two (2) were from providers that the site had never used before. Since this change was coming from the safety group AND the change was initiated to IMPROVE SAFETY – no one thought that a MOC may be useful, necessary, or required. Personally, and since I write a finding against this in the audit, I believe this to be a failure of the MOC requirements – some may disagree.
The facility decided to go with a new brand and all their bells and whistles. This meant an entirely new operation of the new meters (bump testing, fresh-air setups, screen navigation, heck just turning them on and off) new calibration schedules, new calibration gas, new “off-the-shelf” alarm set points that did not match the facility limits, new alarm tones, etc. As we can see, it was a significant change which would end up impacting over 250 employees who issue work permits, serve as Fire Watches and Entry Attendants, as well as the entire safety team (14 members). This meant new training materials would have to be developed, training provided. And as with most “changes” it is the little items that cause us the biggest issues: 1) the inventory system would have to be revised to reflect the new calibration gas cylinders, which actually increased in price as well, 2) but the biggest issue the facility encountered was they needed a much bigger area for the new charging/bum test stations and anyone who has been inside a “control room” know that space is very limited, as are power outlets!
During our interviews, we could sense a tad bit of frustration with how this “change” was “managed”, as it took them well over a year to get all the units in the facility swapped over to the new instruments. This led to huge budget over-runs (having to keep two brands in operation) and caused a lot of confusion across the centralized maintenance team and contractors.
Thinking through these challenges via the MOC model would have allowed the facility to identify the procedural needs, training needs, and equipment needs before the new units even arrived on site. And unfortunately, the new training materials included a lot of the older information; however, these new meters came with their own new set of limitations of which were not included in the new training materials and thus personnel were not aware of some critical limitations.
A simple, albeit extensive MOC review, could have aided this safety team in this change in a big way – whether we agree that it is a compliance issue or just a failure to use a change management tool – a MOC would have made a huge difference in such a vast change.
NOTE: During the audit, we spent a lunch break, looking at what would have happened had the facility stayed with the same brand, but a newer model of the instrument. As it turned out, even with the same brand – but a new model, the same impacts would have been present and a MOC would have been useful.