I joke with my HAZMAT students that I am going to dress up as “IDLH” and scare everyone on Halloween and I joke with my PSM students that I am going to dress up as a MOC and scare everyone; it’s just meant to be a joke, but one day someone asked me… “What would you look like if you dressed up as a MOC”? His question got me to thinking… what should a MOC look like?
Most of us think of a “checklist” of sorts when we have a mental image of a Management of Change (MOC) document, but in reality, a MOC should be so much more. When I worked for BFGoodrich Chemical, they had the most extensive MOC requirements and still the best I have ever seen. BFG saw the MOC process as a request to make a change and in order for everyone necessary to approve said request there had to be a lot of information and data provided UP-FRONT before the MOC could even be approved to go forward. It went something like this:
Change: Replace Pipe Circuit #1 due to aging and NDT results with SS316 rather than CS.
The MOC package would include the specifications for the pipe to be used: schedule of pipe, materials of construction, welding methods, etc.
The MOC would also include:
- identify the PSM/RMP approved contractor to do the work
- Contractor has to be approved for welding pressure piping (has an approved WPS for the project), as well as work in a PSM/RMP process
- the pressure testing and leak testing requirements that would be followed for its installation
- Depending on the RAGAGEP used (B31.3 or 31.5) the pressure testing and leak testing differs so the MOC must state the test procedure (hydro vs. pneumatic) and what pressures will be used. A good MOC will require a specification test procedure be developed for the new section of pipe to be installed.
- the labeling that would be applied to the new pipe
- This labeling should be specific as to the color of labels (background and lettering), the size of the label(s), the location of the label(s), and the contents of the label(s). Stating “labeling will be done per ASME A13.1” is not a detailed labeling plan.
- the insulation spec to be used if the pipe is to be insulated
- If the pipe is to be treated before the insulation is applied, this must be stated and spec’ed out. The company specific insulation spec can be referenced for details; however, IF the change will be put into service BEFORE the insulation is in place, this MUST be evaluated OVER AND ABOVE this basic MOC!
- the information to update the MI inspection Work Order for Pipe Circuit #1 (as the NDT inspection dates will be revised and maybe no longer have to be worried about CUI issues
- Changing the materials of construction within one pipe circuit may involve quite a bit of updating to the MI program, especially if this is the first piece of SS piping used. In fact, the MOC coordinator may need to create an entirely new pipe circuit for this new pipe run that will be SS, which means a new W.O. will be needed with new inspection dates, etc.
- Which P&IDs and ISO’s will be updated
- This will be dependent on the information contained on the P&IDs and ISOMETRIC Drawings, but if these drawings contain the materials of construction for the pipe circuits then they will need to be updated. We expect to see a full listing of all the drawings that will be updated.
- Which SOPs will be updated (if any)
- This will be dependent on if any SOPs will need to be updated based on the scope of the change; in fact, changing the materials of construction for a pipe segment will most likely not involve any revisions to the SOP(s).
- Which Maintenance Procedures will be updated (if any)
- This will be dependent on if any MPs will need to be updated based on the scope of the change; in fact, changing the materials of construction for a pipe segment will most likely not involve any revisions to the MP(s).
- Who needs to be trained on the revised documents (listing by names)
- This part of the MOC can be the most labor intensive, as it will require the MOC requestor to have first established all the documents/procedures that will require revision and then establish which operators would be impacted by these revisions. In essence, most of the engineers would create a “Training Sheet” and place all the names of the personnel who need to be trained on which topics. Some MOCs would have a dozen or more “training sheets” based on the number of documents that would be revised.
- Who needs to be made aware of the change(s) (listing by names)
- same as above.
Now the beauty of such a detailed MOC is that the PSSR becomes very easy! Now all we do for the PSSR is to verify that everything established in the MOC was actually done in the manner the APPROVED MOC said it would be done.
The effort, by engineering, production, maintenance, and EHS, is done in the review of the change and scoping out HOW THE CHANGE CAN BE MADE SAFELY. And as long as everyone approves the change AS IT WAS SUBMITTED and the PSSR validates all aspects were put in place as APPROVED, then we have a SUCCESSFUL CHANGE.