Management of Change (Part 1: The Problem)

When it comes to process safety, one area that is vitally important, yet most still struggle to implement, is management of change (MOC). In fact, the lack of a robust change management process can be traced to the main causal factors in numerous process safety events. There are many ways in which facilities manage change from simple to complex. What is common though in most MOC systems is the failure to complete the basic requirements of a management of change (MOC) system which is to “manage the changes”. For example, most MOC systems, involve completing various checklists and/or attaching documents to the MOC as the change is being completed or even after completion. Some MOC systems are so complex and involve so many levels of approval that they often get bypassed altogether. When the change is simple, engineers, contractors, and other third parties that are involved in the change are more likely to complete the requirements and provide the proper information. Lastly, even when all parties involved understand the process, do the actual equipment files get updated, procedures get revised, and training provided on the change completed with verification of understanding? Compliance audits conducted in all industries reveal, in most cases, the answer is no. The problem is, how can the MOC system be simple to use, ensure equipment files (PSI) and procedures are accurately updated and maintained, and the training that is provided is more than just a sign-off by operations personnel.

In the next few articles, we will attempt to simplify the MOC process, and then suggest methods and tools to make the process simple and easy for all parties involved. A simple but effective MOC process can achieve that higher level of process safety.