Management of change is a best practice for controlling health, safety and environmental risks when an organization makes changes in their facilities, procedures, personnel, processes and manufacturing operations. MOC is a formal protocol required by the Occupational Safety and Health Administration (OSHA) under its Process Safety Management standard. OSHA 1910.119(l)(1) sets the requirements for MOC as: “The employer shall establish and implement written procedures to manage changes (except for ‘replacements in kind’) to process chemicals, technology, equipment and procedures; and, changes to facilities that affect a covered process.”
Here are some bad excuses for not following an MOC process, which leads to process safety incidents:
- But I am not making a real modification. I am just making it a little better.
- I am so far behind I can’t start doing MOC. I’ll never catch up with all of those unrevised drawings.
- I don’t have time to wait for the MOC evaluation. This is an emergency!
- Routing this form for approval takes so long we can never get anything done.
- But my area manager already has to approve funds for changes.
- We are a warehouse/light manufacturing/data center/repair facility. We don’t have anything that could be dangerous.
- But MOC won’t catch every possible problem, so why do it?
- This is just a software/procedure change. It’s not like we were changing a pipe or something. We don’t need to approve or document.
A well-designed MOC process is an essential loss prevention tool for any business. It is not just for certain hazardous industries. The process applies to any company that wishes to avoid future losses resulting from today’s changes. MOC does not have to be overwhelming or so difficult to use that it inhibits change. It cannot effortlessly compensate for past omissions, only reduce your future risk. So, the time to start developing and implementing an effective and efficient MOC process is today.
Because every business has different areas of risk exposure and different tolerance of undesired consequences, it is up to each business to assess risk and define its tolerance for uncontrolled change. A few examples of the sorts of changes a business may wish to manage are:
- Addition of new process equipment or critical business system (including software).
- “Not in kind” replacement of process equipment or parts.
- Modifications or minor additions to process equipment.
- Modifications or minor additions to critical business systems (procedural or software).
- Modifications or minor additions to infrastructure/non-process equipment.
- Changes to process control and/or instrumentation (includes control strategies).
- Changes in specifications or sourcing of technical MRO.
- Changes in critical process parameter operating limits (outside of ranges specified in standard operating procedures [SOPs]).
- Alterations to safety systems (interlocks, shutdowns, fire or explosion suppression, etc.).
- Revisions to standard operating procedures (including emergency procedures).
- Changes in site-level organizational structure.
- Changes to maintenance procedures.
- Changes in raw material/component specifications or sourcing.
- Alterations or new connections to utilities systems (air, electrical, gas, water, steam, etc.).
- Alterations or new connections to critical data networks.
- Changes to QA procedures or critical test equipment.
A few hours of quality “what if” brainstorming by a multi-disciplinary team early in the process design to develop the definitions and examples that are right for your business will pay huge dividends.
MobilOps MOC is a web-based collaboration and workflow software designed to manage changes systematically in process chemicals, technology, equipment, facilities or procedures. It tracks all planned changes through a series of checklists and workflow phases to ensure your business is fully prepared to implement any operational or organizational change. This application is ideal for those subject to OSHA’s Process Safety Management (PSM) requirements, as well as those interested in PSM management of change software as part of a best practices management approach.
- Implement any kind of change.
- Create unlimited workflow templates with customizable steps, tasks and people; define your own workflow action and rules.
- Link documents, equipment, P&ID’s.
- Set up flexible people review structure (parallel, sequential, any individual or group review).
- Enforce completion of critical tasks at any step within the MOC process.
- Manage temporary changes.
- Seamless email notifications during the life cycle of MOC including reminder emails.
- Create your own email templates for each event with in MOC.
- Standard reports and customize your own reports.
- Implement any type of changes including “not in kind” equipment, process, procedures, technology, organizational changes and many more.
- Common tracker module to track all action items from MobilOps apps.
- Create unlimited checklists including PSSR, PHA and others.
- Attach checklists to approvers and tasks implementers.
- Attach standard and custom forms to any step within the workflow.
- Control access to data based on user roles and permissions.
- Visual display of workflow chart and workflow steps.
- Dashboard with graphical charts.
- Easy-to-use, web-based application developed based on powerful Microsoft .Net Technology and Microsoft SQL Server Database.
MobilOps provides web and tablet-based enterprise software applications that enhance safety, productivity and compliance in heavily regulated and high-risk chemical, energy, oil and gas, and construction companies.