Promoting Safe Practices through Management of Change

Electronic MOCs have given all affected personnel easier and more effective access to the information required to be reviewed prior to operating the process, says Mike Whitten, a speaker at next month's marcus evans 3rd Process Safety Management Conference for the Chemical, Petrochemical, & Refining Industries.

• By Robin Yegelwel
• Aug 20, 2012

The chemical, petrochemical, and refining industries utilize some of the most dangerous materials in very capital-intensive processes with great risk to personnel and assets. The accidental release of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals can be catastrophic due to the human, financial, and business costs of an incident.

These industries and their HSE executives are committed to executing best practices to maintain a safety-minded culture and prevent highly critical assets from failing.

The marcus evans 3rd Process Safety Management Conference for the Chemical, Petrochemical, & Refining Industries, taking place Sept. 12-14 at the Sheraton Suites Houston in Houston, Texas, will promote awareness of the evolution of risk mitigation and safety processes by providing practitioner-based case studies on the latest regulatory concerns and tools to improve PSM efforts. They include Layers of Protection Analysis (LOPA), Management of Change (MOC), Process Hazard Analysis (PHA), Mechanical Integrity, and more.

Management of Change is the element from which all other "foundation" elements of process safety management (PSM) are implemented and controlled. There are several challenges PSM professionals face when implementing an MOC, such as analyzing risk, recognizing change, and efficiently managing alterations. Mike Whitten, Process Safety Management coordinator at Koch Nitrogen Company, LLC, and a speaker at the conference, answered a series of questions provided by marcus evans. The responses to these questions strictly reflect the views and beliefs of Mike Whitten and not necessarily those of Koch Nitrogen Company, LLC.

ME: In your opinion, what are the most prominent issues that should be covered when evaluating and recommending change?

Mike Whitten: Truly understanding if the proposed change is not like-in-kind and having a clear technical basis and description of a change so that an adequate technical hazard review can be conducted.

ME: In what ways can a company demonstrate conformance in control documents for Management of Change?

MW: Most Management of Change programs typically include some type of checklist to support the required technical/safety design reviews. This documentation in conjunction with any supporting documents derived from the technical review should be considered, controlled documents that conform to the Management of Change requirements.

ME: What is the most effective way for changes to be communicated to employees before they become involved in operating the equipment/process changes?

MW: The most effective communication would be formal, face-to-face meetings; however, this is not practical in most cases. Some other options used have been making hard copies of all MOCs available in control rooms whereby operators have been required to review and sign acknowledging understanding of the changes that have been made in their absence. Now, with the advent of electronic MOCs, operators (and all affected personnel) may have easier and more effective access to the MOC information required to be reviewed prior to operating the process. Some databases have the ability to time stamp when an operator opens and reviews the MOC records. There are most likely many other effective means; however, these are two examples of means of communicating changes.

ME: In what ways can a Management of Change process be initiated into an organization?

MW: From a compliance with PSM perspective, it has always been effective to start with a review of the 1910.119(l) [OSHA standard] to ensure understanding of why there is a need for a Management of Change process. From there, providing training on the Management of Change procedure and working through examples of not like-in-kind changes should result in a fairly effective means of driving an MOC process into the organization.

The Pre-Conference Workshop A on September 12 at 1:30 p.m., prior to the conference, will enable attendees to evaluate current practices and procedures for MOC, demonstrate conformance to written programs to control and mitigate risk, focus on continuous improvement and assessment processes to ensure sustainable compliance, and more. For more information regarding this conference and to register, visit http://www.marcusevansch.com/PSM_Interview_MikeWhitten or contact Robin Yegelwel at 312-540-3000, ext. 6483 or [email protected].