More Related Content Similar to PHMSA - API RP 1173 - Management of Change - Overview (20) PHMSA - API RP 1173 - Management of Change - Overview2. Copyright, © 2017, Lean Compliance Consulting, Inc.—All rights reserved
WHO WE ARE AND WHAT WE DO
Lifting the weight of Regulation
Copyright, © 2017, Lean Compliance Consulting, Inc.—All rights reserved
Our purpose is to help you achieve better outcomes in keeping people, assets,
and the environment safe.
Companies in every sector need compliance processes to meet ever increasing
regulatory, safety, environmental, and social demands.
Traditionally, compliance is seen as an overhead or an afterthought and not
part of the business process. This is similar to where quality was in previous
years. Just as with quality, compliance needs to be designed into the process
an embedded into the day to day work practices.
This is not helped by implementing top down programs that are "heavy" in
comparison to the "lean" culture and workflows found in today's operations
and manufacturing environments.
Lean Compliance uses the LEAN mindset, tools, and techniques and applies
them to compliance resulting in sustainable processes with continuous
improvement.
5. MOC PIPELINE SAFETY
Brief history of Pipeline Safety Management of Change
§ 40CFR192 introduced in 1970
§ MOC 40CFR192 Introduced in 2003
§ Integrity management program based on ASME/ANSI
B31.8S[11]
§ Covered Segment defined as High Consequence Area
§ More detailed than OSHA
PHMSA – 40CFR192
§ 1910.119 introduced in 1992.
§ Process chemicals, technology, equipment, and
procedures; and, changes to facilities that affect a
covered process.
§ MOC triggered by change in design basis
§ Covered Process
§ Exception: Replacement in Kind (RIK)
OSHA – 1910.119
§ RP 1173 introduced in 2015
§ Types of changes include: technical, physical, procedural
and organizational
§ Covers all aspects of owning and operating a pipeline
§ Level of detail should be appropriate for the size of
operation and the level of risk
PHMSA – RP1173
§ 40CFR68 introduced in 1994
§ Process chemicals, technology, equipment, and
procedures; and, changes to stationary sources that
affect a covered process.
§ MOC triggered by change in design basis
§ Covered Process defined differently than OSHA
§ Exception: RIK and naturally occurring hydrocarbon
mixtures
EPA – 40CFR68
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8. PHMSA RP 1173
Management of Change
8.4.3 Elements of MOC Process
A MOC process shall include the following:
1. Reason for change,
2. Authority of approving changes,
3. Analysis of implications
4. Acquisitions of required work permits
5. Documentation (of change process and the outcome
of the changes),
6. Communication of changes to affected parties
7. Time limitations
8. Qualification and training of staff.
NOTE 1: Refer to ASME B31.8S for gas transmission pipelines
and API 1163 for hazardous liquid pipelines
NOTE 2: Application of MOC may trigger use of risk assessment
to evaluate the impact of change on overall risk.
Note: These requirements can be addressed using a structured process tied to practices from supporting elements (for example:
risk management)
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9. Copyright, © 2017, Lean Compliance Consulting, Inc.—All rights reserved
Managing processes requires different skills than managing
individual activities. Pipeline process management includes
determination of needs throughout the pipeline lifecycle,
provision of sufficient human and financial resources,
identification of the proper sequence of a series of activities,
monitoring and measuring the effectiveness of the activities
performed, and applying changes or corrections to those activities
as needed.
PHSMA RP 1173 (Managing the Safety of Complex Processes)
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10. MOC PROCESS
RP 1173 requirements – Part A
INITIATION
• Change description
• Type of change: technical, physical,
procedural, organizational
• Reason for change
• Time limitations
IMPACT ANALYSIS
• Identify implications of change
• Conduct risk assessment
• Identify affected parties
APPROVAL
• Approve implementation of
requested change
DESIGN
• Identify design alternatives
• Select preferred option
PLANNING
• Develop implementation plan
• Identify required work permits
IMPLEMENTATION
• Execute
implementation plan
• Notify affected parties
• Conduct necessary
training and
qualification
INITIATION
IMPLEMEN
TATION
DESIGN
IMPACT
ANALYSIS
PLANNING APPROVAL
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11. MOC PROCESS
RP 1173 requirements – Part B
VERIFICATION
• Inspect work
• Conduct Pre-startup Safety Review
CLOSE-OUT
• Document change process and outcome of changes
• Update affected documents and records
• Conduct lessons learned review
VERIFICATION CLOSE OUT
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Summary
§ RP 1173 requirements can be
addressed by using a structured
process and applying lean principles to
ensure the right steps get down at the
right time.
§ May require additional tools if not
already part of current process:
§ Risk Identification, Assessment,
and Treatment
§ Impact Assessment
§ Stakeholder Communications
§ Lessons Learned Register
17. § Identify stakeholder (or customer)
value
§ Map out the process and data flow
§ Identify and remove areas of waste
§ Identify and address compliance
gaps
§ Streamline work flow and Establish
Pull
§ Create implementation plan and
implement your next step
NEXT STEPS
Map value stream and identify areas of process and data waste
Copyright, © 2017, Lean Compliance Consulting, Inc.—All rights reserved
Map
Value
Stream
Remove
Waste
Address
Compliance
Streamline
Flow
Implement
Next Step
Identify
Value