For the life of me, I can not figure out the aversion to doing MOCs. I am guessing that my experiences in Petrochem were not the norm, as we used our MOC process for just about everything under the sun. Heck even the QC group used our MOC process. We rarely questioned the value of doing an MOC and the MOC process was fully accepted as a way of managing changes irregardless of what OSHA or EPA required. As such I saw many occasions where the MOC process saved my behind; especially in my early days as a safety manager doing PSM. Here are some of my learning’s…
MOC on personnel changes is a GREAT method to ensure the transition of people changing jobs does not fall through the cracks. The MOC should not be viewed as merely a means to evaluate a replacement; heck, we should have a job description for the role and HR should have posted all the necessary skill sets needed for the new hire who will be taking over the role. The interview process is where we do that evaluation. What the MOC process does is bring management together to review the process in how that person’s tasks are going to be managed UNTIL the new person is in place. A lot of management groups may not fully understand what this person does on a daily basis so with the person leaving in the next two weeks we have to develop a plan to cover all their responsibilities and tasks until the new person is on board and capable of completing said tasks and responsibilities. If the person leaving is a key member of your process safety team, we need to identify those activities that will come due over the next 3-6 months. Items like PHAs, Audits, RMP updates, EHS Action Items he/she is assigned, etc. These responsibilities and tasks need to be divided up among capable personnel so that the management system continues on. Of course, if the facility has an advanced safety management system and management is already highly engaged in the safety management systems, this transition will go smoothly. On the other hand, if management thinks “Safety is the Safety Dept’s job” this will be an eye-opening exercise for many of them.
Here are a couple of related programs that could be impacted by a change in the safety department staffing:
- RMP Emergency Contact may need to be updated within 30 days
- Action items from PHA’s, Audits, II’s, etc. may need to be reassigned
- Someone may need to become qualified to facilitate PHA’s
- Someone may need to become qualified to lead root cause analyses
- Emergency Response Plan Incident Command System may need to be revised
- Respiratory Protection Program Administrator may need to be revised
- You may be losing a person from your day shit ER coverage for CS Rescue
- Who will sign off on the MOCs and PSSRs and do the Safety Reviews of changes?
- Who is going to manage all the new SDSs arriving on a daily basis over the next several months?
- Who summarized and got the Plant manager to sign the 300 Log and posted it?
Until someone departs, we often times never really think about ALL that they do. Use their “2-week notice” as the time to manage their departure using the MOC review process to make sure nothing they do falls through the cracks.
MOCs on changes to SOPs and SWPs
For years I always expected an MOC to be done on all changes to PSM/RMP related documents. This included all of our Safe Work Practices (SWP) directly related to operators, maintenance and contractors associated with a covered process, Emergency Action Plan and Response Plan (including Pre-Plans), contractor safety program and training program, etc. Heck we even required an MOC on equipment added within a process battery limits even though it was not part of the process and it was thought to not have an impact on the process (e.g. not a “covered” piece of equipment as it is not interconnected nor “co-located” in a way it can impact the process safety). But we looked at needed procedures for the operation and maintenance of the equipment, noise issues it may cause, potential exposure issues, guarding issues, training needed, spare parts needs, entry into the PM management system, LOTO procedure for the equipment, does it need to be evaluated as a CS/PRCS, is the ladder/stairs attached to it to code, etc. But it went without saying that if we revised our LOTO program, any machine specific procedures (including adding a new one), revised our LOTO permit, added an authorized employee, etc. an MOC was done to manage this change. If we added or removed a PRCS, revised the CS program, an MOC was done. For those SWPs specifically called out in 1910.119(f)(4) we treated as if it was a PSM/RMP SOP or maintenance procedure, but we also found value in doing MOCs on all the other SWPs that impacted our PSM/RMP personnel.
Example: We did an MOC when we changed from one brand of SCBA to another because the storage requirements were different, the bottles were a different type requiring a different Hydro schedule, the inspection procedures provided by the manufacturer were different thus requiring us to retrain those who conducted the inspections as well as we had to revise inspection sheets, etc. The ERP had to be revised as our “PPE Inventory Changed”. SCBA’s were used in all of our PSM/RMP processes by operators, maintenance, and some nested contractors; as well as the emergency response team. What may seem like a minor change to some, we viewed as a massive change that impacted written programs, inspection procedures in the maintenance PM database, training programs; all of which would impact over 200 people in some way. But the beauty of the MOC was that it forced us to develop an action plan for the change, assigning roles and responsibilities to qualified personnel. The day the SCBA’s arrived all the had left was the execution of the hands on “trainer the trainer” with the manufacturers rep. All the programs, inspection sheets, training materials, etc. were ready to be implemented.
MOC on changes to staffing
I have written on this topic before, but I can not stress the significance this type of MOC can play in process safety. I have learned the hard way from both OSHA inspections and Incident Investigations that having adequate staff to respond to process demands is FUNDAMENTAL to process safety. I have heard it said far too many times
“our process pretty much runs itself – operators are merely present to make adjustments”
Yet we have not found any engineering company or installation contractor that will provide that in writing for the PSI files!!! We may have convinced ourselves that our operators are not necessary to safely operate the process, but nothing could be further from the truth. Besides, how insulting is this attitude towards the operators? I, nor anyone, can spend a week (or two, or three, or four, etc.) at a facility and make a simple determination of staffing needs. Much like other aspects of process safety, the need is every changing. But I do HIGHLY recommend that ALL SOPs include a staffing element, much like OSHA/EPA require for the Emergency Shutdown SOP. Process incidents over the past 20 years have shown us that START-UP after maintenance or emergency shutdown is HAZARDOUS TIMES in a PSM/RMP covered process. So establishing a minimum number of qualified operators, maintenance, engineering and supervision in your Start-Up SOP(s) is a great idea. In some of our processes, we even went as far as requiring a minimum number of emergency response personnel be on site and this number varied from process to process and for some processes, this meant personnel were on the site solely serving in the capacity of an emergency responder and not in their normal job.
Anytime these staffing levels were increased or decreased an MOC was done to manage the change.
The Management of Change element was put in place to ensure changes that could impact the safety of the process and those working in, on, and adjacent to the process were managed properly to ensure continued safety. It is not a piece of paper we have to fill out in order to get purchasing to order the equipment! It matters not how long (or short) your MOC documentation is, as long as it covers all the necessary elements. Too often we get caught up in how a 25-page checklist will be received by others; when in reality maybe once a year a change is so significant that all 26 pages are needed. If your process(s) is a large, complex, labor-intensive process then maybe a 26-page MOC checklist is needed all the time; BUT do NOT be fooled into convincing yourself that because your process “only handles flammable liquids and involves a storage tank and one process vessel” that the MOC can be a single page. Whatever is decided, the MOC should be used to manage ALL changes that can impact process safety – REGARDLESS of how insignificant they may seem.