Safetip #86: Include Deviations from Normal Operations in MOC
In November 1998, a fire occurred at an Equilon Enterprises oil refinery. Three years later, the U.S. Chemical Safety Board (CSB) issued a Safety Bulletin to focus attention on the need to manage safety effects of process changes in the chemical industry. The bulletin discusses the Equilon incident and another one that occurred also in 1998. Both incidents highlight the importance of having a systematic method for MOC.
Apply an MOC Methodology to Operational Deviations & Variances Also
The CSB’s safety bulletin emphasizes strongly the need to apply an MOC methodology to operational deviations and variances also, in addition to pre-planned changes, such as those involving technology, processes and equipment.
Organizations apply sometimes systematic methods for managing change in the physical environment, such as the addition of new equipment or a replacement equipment different from the original. But MOC policies that cover deviations from normal operations should also be established, including abnormal situations, changes to procedures, and deviations from standard operating conditions.
According to the CSB bulletin, for an MOC system to function effectively, field personnel need to know how to recognize which deviations are significant enough to trigger further review. Operating procedures must specify well-defined limits for process variables for all common tasks. After workers are trained on MOC policy and are knowledgeable about normal limits for process variables, they can make informed judgments regarding when to apply the MOC system.
Management Has a Responsibility to Handle and Approve Deviations
Once a deviation is identified and triggers the MOC system, management must gather the right people and resources to review the situation, identify potential hazards, develop protective measures, and propose actions. Based on the complexity of the change or variance, a formal hazard analysis may be needed.
The deviation or variance must be approved by the appropriate level of management, based on the risks involved. Also, they should be documented to have a consistent understanding of what specific departure from normal practice is allowed, the CSB bulletin says.
Finally, the implementation of MOC policies can be greatly facilitated through change management software. The software system allows organizations to define different types of changes, including operational changes, and automatically trigger the specific change management process associated with the corresponding type of change, thereby mitigating risks and ensuring safety at facilities.
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