management of change procedure is important to implement EHS in any organization.

1. Welcome in the training section of
Management of Change
Vishnu K. Gupta
QA-System compliances manager
LCL Jodhpur ,
“Working Safe, Preventing Injuries, Increasing Profits”

2. Overview
• What is Management
of Change (MOC)?
• Why do we need
MOC?
• Recognizing Change?
• The MOC Program?
– Main Elements
– Operation
– Keys to Success

3. Management of Change
Policies and procedures which ensure that changes
do not result in operations outside of established
safety parameters Essential element in an
organization’s process safety system
Managing change can mean managing potential
incidents

4. Focus of MOC
• To prevent catastrophic
accidents and to properly
evaluate the concerns of
safety and health and to
accomplish this review in a
timely manner.

5. History of MOC
• Early 60s - Formal procedures first introduced in
the nuclear power and defense industries.
• 1976 - First mention of use within chemical
industry at Loss Prevention Symposium
• 1985 - CCPA pamphlet, “Essential Components of
Safety Assessment Systems
• 1990 - API recommended practice “Management
of Process Hazards”
• 1992 - OSHA 1910.119, “Process Safety
Management of Highly Hazardous Chemicals”

6. MOC and Process Safety Management
•Process Safety Management is a method of identifying,
understanding, and controlling process hazards and preventing.
• Process-related injuries and accidents.
•MOC is one of the PSM elements.
•MOC is never complete - must be performed on a continual basis
throughout the life of the process.

7. Why do we need MOC?
• 80% of all large
scale accidents in
the process
industries trace
their origins back
to “Change”.
• Change is essential
to a company’s
survival
– they have to be able
to continuously
improve their process
and keep up with
industry standards.
VS.

8. Case Study: Flixborough, 1974
• Vapor cloud explosion - fueled by release of 30
tons of cyclohexane
• Largest single loss by fire or explosion in the
United Kingdom
– killed 28 people
– injured 89 others
– $63 million in property damage

10. The Flixborough explosion…
was the result of an unwise plant maintenance
modification.
In Hindsight ...
• A proper MOC procedure could have prevented
this accident.
• One of Main recommendations from inquiry
– Any modification should be designed, constructed,
tested, and maintained to the same standards as the
original plant.

11. Does the our Industry ever need to
Manage Change?

12. BP Refinery in Texas City, 2005

13. BP Refinery in Texas City- Findings
• There were a number of misapplications of
the refinery MOC policy for changes
pertaining to the blowdown drum, the
splitter tower, and occupied trailers.
Chemical Safety Board - BP Texas City Final Investigation Report
3/20/2007 pg. 138

14. BP Refinery in Texas City- Findings
• Organizational changes that could adversely
impact process safety, such as changes in the
management structure, budget cuts, etc., generally
were not evaluated.
Chemical Safety Board - BP Texas City Final Investigation Report 3/20/2007 pg.
139

15. Macondo Blowout and Explosion, 2010

16. Lessons not learned….
“Despite some significant progress with process
safety indicator implementation in the downstream
oil industry…
in the offshore sector -BP, Transocean, industry
associations, and the regulator had not effectively
learned critical lessons of Texas City and other
serious process incidents at the time of the
Macondo blowout.”
Chemical Safety Board findings 7/24/12

17. Lessons not learned…
“Systems for managing the safety of process
changes were inadequate. The plan to complete and
“temporarily abandon” the Macondo drilling
operation was changed five times during the week
before the disaster, but there is no available
documentation that management of change
procedures or formal hazard assessments were
conducted.”
Chemical Safety Board findings 7/24/12

18. What is Change?
• Most difficult part of Management
of Change is recognizing change.
• Need to be able to distinguish
between a change that requires
approval using the MOC procedure
and one that does not.

19. Recognizing Change

20. Replacements-in-kind
• Defined - a replacement that satisfies the
design specifications.
• Examples
– raising reactor temperature within safe
operating envelope
– replacing equipment or piping meeting the
same specifications as the original

21. Change
• Change is an alteration or adjustment to any component,
variable or property within an existing system (except
those within clearly defined boundaries or responsibilities).
• Examples
– changes that alter production rates
– changes involving safety relief or vent systems
– deteriorating materials

22. Main Types of Changes
• Change of Process
Technology
• Change of Facility
• Organizational Change
• Variance Procedures
• Personal Change

23. Permanent vs. Temporary
• MOC should be
conducted on
both permanent
and temporary
changes.

24. Key Elements of a Program
• Identification System
• Change Control Mechanism
• Training
• Information Management System
• Auditing

25. Identification System
• Screening process for
identifying changes.
– Includes risk ranking process
based on effect item could
have on safety of process
• Requires clear, written,
definition of system
boundaries and what
constitutes “change”

26. Change Control Mechanism
• Explains how to manage
the change.
• Must clearly identify:
– the work flow procedures
(MOC form)
– responsibility and
authority
– approval level

27. Training
• Anyone who could
affect a change must be
properly trained in the
Management of Change
system
• Commitment from all
levels of management
and staff

28. Information Management System
• “Status Accounting”
• Software/documentation
that tracks all changes and
their progress
• Allows access to most
current information
– ie. If two changes are inter-
related they will be aware of
one another

29. Auditing
• Ensures system is working
as it should
• MOC system should be
constantly evolving and
improving in efficiency
and effectiveness
• Verifies changes are
assessed accurately
• More often while the
system is new to ensure all
the “bugs” are found

30. Operating the MOC system

31. Standard Operating Procedure (SOP)
SOP
No.
LCL/EHS/003/003
Subject: Management of Change
Original
Version No:
01 Date: 20-Dec-14 Revision
No:
00 Date: 20-Dec-14
Purpose: Management of Change Procedureis developed to ensure that changes are
properly reviewed and approved by persons with the required expertise prior
to implementation, to eliminate workplace hazards that could lead to injuries,
equipment damage, production losses,product quality,project reputational
impact or environmental impacts.
Responsibility: Head of the department, SHE Manager

32. Definitions, if any: 1. Major Impact Changes: A change expected to have an impact on EHS &product quality. Changes with
an uncertain impact level should be handled as major impact changes.
2. Minor Impact Changes: A change not expected to have an impact on the EHS &product quality.
3. Emergency Changes: An unplanned change of a piece of equipment as a result of an emergency,
which needs to be repaired immediately in order to maintain personal or equipment’s safety, or preserve
the quality of the product.
4. Chemical/Technology changes – include modification of operating conditions of predefined safe
operating limits, alarm or interlock set point revisions, software revisions, interlock logic revisions,
introduction of new chemicals, chemical substitution, and chemical re-introduction.
5. Equipment changes – include new piping/equipment, piping rearrangements, and equipment revisions,
new materials of construction, or design parameters, impairment of fire water systems, impairment of
alarm systems.
6. Procedural changes – include standard operating procedures, emergency procedures, safe work
procedures, temporary operating procedures, maintenance/inspection procedures, temporary operating
procedures, maintenance/inspection procedures or development of a new procedure for new equipment
installations.
7. Personnel/Organizational changes – include a change in the number of people, structure of an
organization, development of a new role in an organization, instrument/electrical or maintenance
support, or contractor for the site or unit, and absence from job for extended period.
8. Temporary change – planned for a limited duration; such as, a trial or evaluation or by-pass of a safety
system for maintenance. Planned operation of a process outside its normal operating range or transfer
of a product from its normal process train to another.
9. Facility change – includes buildings, utilities, containers, process/emergency equipment location and
other non-production related areas.
10. Replacement-in-kind – an item, equipment, chemical, procedure etc. that meets the design
specification of the production it is replacing.

33. Change Initiation:
•Once a potential change is identified, The HOD will initiate change management process.
•He will call a meeting with HODs of impacted departments.
•The impact with an estimate of accuracy and the forecasted effect on the schedule (days/weeks) should be added to the MOC Form.
Any extended comments and relevant backup documents should then be attached to and become part of the MOC Form.
•All HODs involved can question the change.
•All questions must be resolved before the MOC can be approved for implementation.
•Reviewers may reject the change if their concerns are not addressed through risk assessment or identified mitigation measures
being implemented.
Common Justifications for a Change:
Any change in the current management system, equipment’s, specifications of raw materials/ finished goods/intermediate/ packaging
materials & labels, process parameters, supplier, people need to be assessed with impact on the Quality, Health, Safety and
environment. The reason of change need to be justified appropriately.
There is accountability for proper change implementation. Change Management review procedures will address both permanent and
temporary changes. Temporary change reviews and approvals will specify the duration of the change and will require review if an
extension is required. Temporary changes are to be considered in the same manner as permanent changes.
NO. TYPE OF ISSUE DESCRIPTION
1 FSMS or HACCP Impact If there is change that affect the food safety of products and HACCP of process.
2 EHS The change will potentially affect the health and safety of persons, or protection of
the environment and Community, during fabrication, construction, commissioning,
operations, maintenance or decommissioning. The change could be outside of the
scope of approvals received and may require additional approvals/notifications.
3 Functional The facilities cannot function/be operated /be maintained
4 Constructability The facilities cannot be fabricated or constructed as designed or specified.
5 Statutory The change is necessary to comply with legislation or other mandatory
requirements.
6 Schedule The schedule may be at risk if the change cannot be accommodated.
7 Procurement Supplier cannot meet previous commitments and obligations. New Raw Material
introduction. Change in specifications etc.
8 Security Exposure to security risk is increased/decreased
9 People Assignment, job role change, resignation of employee.
The most common justifications for changes are listed as following:

34. MOC Notification:
The assignment of numbers onMOC Forms shall be responsibility of the SHE Manager. The MOC Form, with any associated reference documen
The impact with an estimate of actions and the forecasted effect on the schedule (target dates) should be added in the actions of MOC.
All MOC are to be signed by the Factory Manager & MR
A list of MOC with MOC Number shall be maintained by SHE Manager.
Type of Changes
All types of changes as specified in definitions need to be considered during review.
Management of Change Review not required for:
•Equipment (vessels, agitators, heat exchangers, etc.) fabricated exactly to the original design and specification or existing approved design
and located in the same position as the original.
•Equipment and materials that are manufactured by an approved supplier toa standard specification, such as bolts, gaskets, flanges, steam
traps, piping, insulation, structural steel.
•Instrumentation (transmitters, pressure and temperature gages, etc.) of the same specification and range, and purchased from an approved
supplier. A change in instrument type e.g. RTD to thermo-couple does not constitute a replacement in kind. Electric motors, fuses and circuit
breakers of the same specification from an approved supplier.
•Replacement of piping with the same size, material, flange make-up and routing as the existing.
MOC
Checklist-Format.doc
Developed by: Vishnu Gupta Reviewed by: Milind Musale Approved by: Dr. Sanjay Modi

35. MOC Form
• A MOC form is used by company
to guide employees through the
procedure
• The MOC form should include:
– Description, purpose, and technical
basis for the change
– Assigned level of risk
– Safety, Environmental, and Health
impacts
– Necessary time period for the
change
– Authorization for the proposed
change

36. MOC
Checklist-Format.doc

37. Ranking changes
– Major Impact Changes:
– Minor Impact Changes :
– Emergency Changes
– Chemical/Technology changes
– Equipment changes –
– Procedural changes –
– Personnel/Organizational changes –
– Temporary change –
– Facility change
– Replacement-in-kind
– Don’t manage all changes with same rigor
• Hazard analysis method and level of approval dependent
on type of change.

38. Determine Hazard Level
• Examples of yes/no questions to
determine the hazard level:
– Does the change introduce a
significant source of energy
(chemical, mechanical, thermal,
electrical)?
– Does the change result in any
increase of toxic, flammable, or
reactive material?
– Does the change significantly
increase the potential for personnel
exposure to a hazardous material?

39. Determine Potential Severity
• Examples of yes/no
questions used to determine
potential severity level:
– Could the change take
the process outside the
safe operating
envelope?
– Does the change
significantly alter the
heat and material
balance?
– Does the change
introduce new
molecules?

40. ...
• Management Support
• Implementation not just
documentation
• Understanding and
utilization of developed
procedures
• Training
• Essential to keep
stakeholders informed
throughout the MOC
process.

41. Conclusions
• Unmanaged process and organizational
modifications have been a major cause of
accidents.
• A formal method to deal with change will
help prevent future accidents from occurring.
• Change is unavoidable in our industry
– all organizations should have a MOC program.

42. Vishnu K Gupta
QA & System Compliances- Manager