I often hear that a management of change (MOC) was not used because the equipment being replaced, was a replacement in kind. A simple example, a process evaporative condenser is being replaced due to Mechanical Integrity issues, the new condenser is a different make and model but meets the definition of “replacement in kind” since it is “a replacement which satisfies the design specification”. This last quote is straight from the regulation itself. However, the process safety information (PSI) will be different no doubt, and based on various RAGAGEPs, the model and serial numbers are considered required process safety information. Too often we debate if the change “satisfies the design specification” when we should be asking three (3) simple questions:
1. Does the proposed change result in manufacture, model, and general specifications changing (Process Safety Information)?
2. Does the proposed change require operating or maintenance procedures to be changed or updated?
3. Does the proposed change have ANY impacts safety and health of employees?
The questions are simple, but it will require an evaluation to determine if the answer is yes or no. Impacts to safety and health does not mean that a full PHA will need to be conducted, but your manage of change policy should indicate how impacts are to be evaluated, and if a formal PHA is to be conducted at some point in the design process. If the questions we ask are ambiguous, such as “Is this a replacement in kind” without some specifics, then you can expect to have changes not managed through your MOC process. Therefore many programs and specifically, process safety information and procedures are no longer current and accurate. Yes, there can be more questions to ask than the three provided, but if you struggle with MOCs, at least work on the basics, since accurate PSI and procedures are core basics to a good process safety management system.
In the next article, we will discuss the overall process itself, 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