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PROCESS SAFETY MANAGEMENT

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TABLE OF CONTENTS

1.

INTRODUCTION .......................................................................................................... 2

2.

SCOPE ......................................................................................................................... 2

3.

DEFINITIONS ............................................................................................................... 2

4.

PROCEDURE ............................................................................................................... 4

5.

TRAINING .................................................................................................................. 10

6.

RECORDKEEPING .................................................................................................... 10

7.

SYSTEM PERFORMANCE ASSESSMENT .............................................................. 10

8.

RESPONSIBILITIES .................................................................................................. 11

9.

ATTACHMENTS ........................................................................................................ 11

10.

REFERENCES ....................................................................................................... 12

11.

APPENDICES ......................................................................................................... 12

Rev.

Issue Date

0.1

20 Jan 2013

01-Apr-12

Amendment Description
Changed RIM to Process Engineering in
the definition of MOC Committee
Chairman.
Major work process revamp and
reclassification of document type from
policy (QC-PSM-PCY-00-0010) to
procedure

Next Scheduled Periodic Review: April / 2015

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Prepared
By

Reviewed
By

Roehl
Bartolome

Carl Poldrack

Roehl
Bartolome

Carl/Venkat

Approved
By

Plant
Management

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1.

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INTRODUCTION
Management of Change (MOC) ensures that environmental, health, safety, and security risks
associated with changes are appropriately managed.
This procedure is intended to establish a consistent framework for any applicable MOC
associated with Q-Chem operations. It is part of the overall effort to manage risks with the
potential for impact to employees, contractors, the public, assets and operations, and the
environment.
The information detailed in this document is intended to comply with the requirements of the
following:
OSHA 29 CFR1910.119 - Process Safety Management of Highly Hazardous
Chemicals
o
Sub section (l) Management of Change (MOC)
Operational Excellence (OE) System
o
Element 2.7 Management of Change

2.

SCOPE
This procedure applies to changes or modifications to process chemicals, technology,
equipment and facilities.
This also covers operations that result in:

The decision to decommission equipment such that it never operates for manufacturing
again.

Ceasing of operation for an unidentified period of time with the potential for restart at an
undetermined date.
The changes listed below are managed through other work processes and are not covered by
this procedure:

Replacement-In-Kind (RIK) changes

One-time deviations to inspection/test/PM schedules, engineering standards and/or


practices, and material reuse/substitution.

Changes to Operating, Maintenance, Laboratory, and other procedures or documents.

Changes at the main administration facility.

Personnel and organizational changes

3.

DEFINITIONS
Change Review Team (CRT): A multi-functional, multi-discipline group responsible for
conducting the hazard analysis for a change. The SME Groups and the MOC Committee are
considered change review teams.
Emergency MOC: Any change or modification required immediately to avoid any one or more
of the following:
An immediate threat to the safety of site personnel or the public;
An immediate environmental release;

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Impending external threats, such as natural disasters or imminent security risks.

The purpose of an emergency MOC is to expedite documentation and change


implementation as a result of an immediate hazard or condition.
Facilitator: The person assigned to coordinate all MOC-related activities.
The different departments or units should assign representatives who would function as
facilitators for their respective groups.
MOC Committee: The group which conducts a higher-level review of a proposed change after
the initial hazard evaluation is completed.
MOC Committee Chairman: A representative of the Process Engineering or PSM Group
assigned to facilitate the MOC Committee Review.
Past Due MOC: A permanent MOC having incomplete post-startup items after 90 days of
approval for start-up, or a temporary MOC that is past its terminal date (90 days after approval
for start-up).
Permanent MOC: Any change or modification that is expected to be in service for a period
greater than 90 days.
Pre-Startup Safety Review (PSSR): A process for ensuring that new or modified processes
are ready for start-up.
Process Safety Information (PSI): Information pertaining to the hazards of any highly
hazardous chemicals used or produced by the process, technology of the process, or
equipment used in the process.
Pre-Startup Action Item: Any MOC-related task that must be completed before new or
modified equipment can be taken into service.
PSM (Process Safety Management) Group: The Head of Process Safety and Compliance
and the Process Safety and Compliance Coordinators
Post-Startup Action Item: Any MOC-related task that must be completed within 90 days of
approval to start-up.
Replacement in Kind: A change or modification that fully meets the design criteria and
specifications of the original item.
RIM (Records and Information Management) Group: The Document Control Supervisor
and his/her staff.
Shutdown MOC: A type of MOC intended to last until the next scheduled shutdown. These
are managed through two permanent MOCs, one for the installation, and the other for the
restoration of the original condition.
SME Group: Subject matter experts of a functional work group. Individual SME groups
conduct the initial hazard evaluation for a proposed change. These include, but are not limited
to, the following:
Production
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Technical I&E
ERG
Engineering
Mechanical Maintenance
I&E Maintenance
Industrial Hygiene
Process Safety
Personnel Safety
Emergency Response
Environment
Marketing
Security
Laboratory

Technical Basis: an explanation of the proposed modification, including the reason for
performing the work, desired results, technical design, and appropriate implementation
instructions. The technical basis should be of sufficient detail to allow appropriate supervisory,
technical, and management review, including addressing the following questions:

What is to be changed and how?


What will be achieved by the change?
How will the change achieve the intended goal?
Is the change safe to make and why?

Temporary MOC: Any change or modification that is expected to be in service for 90 days or
less.

4.

PROCEDURE
4.1. WORK FLOW APPLICATION
4.1.1. MOCs and the corresponding work flows shall be documented and managed through
electronic application/computer software.
In cases where the application is not available, users may revert to the hard copy
MOC form. All information shall be transferred to the electronic system once it is
back in service.
All emergency MOCs shall be documented through the hard copy MOC form.
4.1.2. Specific instructions on the usage of this software are available in Appendix 11.1.
4.2. CHANGE IDENTIFICATION
4.2.1. Any employee or contractor who recognizes a need for change shall complete the
relevant sections of the Change Request Form and submit this to the superintendent of
the originating group.

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4.3. INITIAL REVIEW


4.3.1. The originating group superintendent shall review the change proposal and complete
the applicable sections of the Change Request Form.
4.3.2. If the change is denied, the superintendent shall inform the originator of the denial and
the reason for it.
4.3.3. If the change is approved, the superintendent shall do the following:
Evaluate whether the change is a replacement-in-kind (RIK) or non-RIK by
completing Section F of the form;
Assign a facilitator for the change;
In addition to the mandatory SME groups, determine whether the Security Group
and/or additional SME groups need to evaluate the change;
Determine the risk level of the change by completing Section G of the form;
If What-If or HAZOP/LOPA is required, inform the PSM Group of the requirement.
4.3.4. It is recommended that each area or unit should maintain a list of change proposals
and their status.
4.4. INITIATION
4.4.1. The facilitator shall initiate a MOC in the system by selecting the type and category of
the change, and providing all relevant information about the change.

Types of MOC
Permanent these shall follow the steps in sections 4.4 through 4.12
Temporary these shall follow the steps in section 4.4 through 4.10 and
address the provisions of section 4.13
Emergency these shall address the provisions of section 4.14

Change Categories
Chemicals and Catalysts
Stationary Equipment
Rotating Equipment
Building Siting
Temporary Leak Repairs
Facility Emergency and Safety Equipment (e.g. F&G, deluge, safety
showers, etc.)
Safety Systems (e.g. ESD, SIS, PRD, etc.)
Process Technology and Operations (e.g. production rates, material
balance, etc.)
Instrumentation
Electrical

4.4.2. The facilitator shall ensure the following information is provided in the system:
Unit
Title
Change Category
Description and Scope of Change
Technical Basis
Impact on Health and Safety
Initiation Date
Expiration Date (only for Temporary MOC)

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Estimated Implementation Date


Estimated Close-out Date

4.4.3. The facilitator shall also ensure that sufficient detail and information is provided in the
relevant sections to adequately describe the MOC without referring to other
documentation.
4.4.4. The facilitator shall also upload a copy of the Change Request Form in the electronic
MOC application.
4.4.5. The facilitator shall ensure that documents affected by the change are properly
marked-up and uploaded into the electronic MOC application.
4.4.6. To ensure that the SME Group Review/Hazard Analysis is completed in a timely
manner, the facilitator should specify a time limit for the SME groups to complete their
individual responses.
4.5. SME GROUP REVIEW/HAZARD ANALYSIS
4.5.1. The superintendent or section head of each subject matter expert (SME) group shall
complete an evaluation of the change based on their expertise.
The superintendent shall document the review by completing the appropriate
MOC Hazard Evaluation Form. The facilitator should assist the superintendent by
providing additional details and information about the change.
o Where the change is not applicable to the group, the superintendent shall
indicate the same on the form.
o Where the change applies, the superintendent shall do the following:
Answer each question in the checklist completely including a detailed
explanation for each item;
Identify any action item(s) relevant to the question including proposed
owner(s) and completion date(s);
Review marked-up documents for accuracy and, where necessary,
identify additional information requiring corrections;
List any additional items that need to be discussed in the MOC Committee
Review;
Indicate whether a representative of the group needs to be at the MOC
Committee Review and/or the PSSR.
4.5.2. The facilitator ensures that all SME groups have completed their evaluation and
prepares for the MOC Committee Review.
4.5.3. Where additional hazard evaluation such as a What-If or HAZOP/LOPA is required, the
facilitator shall coordinate with the PSM Group for the conduct of the study.
A copy of the report including a list of the recommendations shall be uploaded
into the system.
4.6. MOC COMMITTEE REVIEW
4.6.1. The MOC Committee shall be composed of the following:
For low- and medium-risk changes: the Committee Chairman, the facilitator, and
assigned SME group representatives;

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For high-risk changes: the same members as above but including the managers
from the originating department and other affected department managers.

4.6.2. The Committee Chairman shall be the process engineer responsible for the unit/area
where the change is proposed.
Where the change is not specific to a particular area, a member of the Process
Safety and Compliance Group shall function as the Committee Chairman.
4.6.3. The facilitator shall schedule the review with the identified MOC committee
representatives.
Process Safety and Compliance Group representatives shall be available to lead
the review meetings once a week.
4.6.4. At the review meeting, the facilitator shall present the change proposal along with the
issues and action items raised by the SME groups.
4.6.5. The Committee Chairman shall facilitate discussion and resolution of all issues
pertaining to the change proposal including a review of the risk level assigned to the
change.
The committee may require additional hazard evaluation (e.g. What-If or
HAZOP/LOPA) for changes that were initially identified as low risk.
4.6.6. At the end of the review, the MOC Committee shall have completed the following:
Final approval of the change proposal;
Finalization of pre-startup and post-startup action items including action owners
and completion dates;
Review and verification of marked-up documents;
Identification of communication and/or training requirements;
Identification of PSSR Team representation and the type of PSSR.
o SME groups who participated in the hazard evaluation should be represented
in the PSSR team.
4.7. IMPLEMENTATION
4.7.1. The facilitator shall utilize existing facility work processes to coordinate construction
and other activities required to implement the change.
4.7.2. The facilitator shall also ensure the following:
All documentation requiring updates have been identified, marked-up and made
available to affected personnel;
All recommendations from the hazard evaluation have been properly addressed;
Any other issues from the preceding steps have been addressed;
The change has been communicated to affected personnel;
Where necessary, develop or update the appropriate training material and provide
training to affected personnel;
Applicable procedures have been marked-up and made available to affected
personnel.

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4.8. PRE-STARTUP SAFETY REVIEW (PSSR)


4.8.1. The facilitator shall schedule and coordinate the PSSR as per the recommendations of
the MOC Committee.
Two types of PSSR checklists, Basic and Comprehensive, are available for use
depending on the complexity of the change.
4.8.2. PSSR Team membership shall be based on the SME Group and MOC Committee
recommendations. However, a representative of the RIM group shall be part of every
PSSR.
4.8.3. The PSSR shall be conducted before start-up, commissioning, engagement, and/or
operations of the change to equipment or facilities, and prior to the introduction of
highly hazardous chemicals to the process for new facilities. The PSSR team must
review the change to confirm the following:
Construction and equipment is in accordance with design specifications.
Safety, environmental, operating, maintenance, and emergency procedures are
adequate and in place.
For new or significantly modified facilities, a process hazard analysis (PHA) has
been performed, documented, and recommendations have been resolved or
implemented before start-up.
Communication and/or training requirements have been completed and
documented.
All other MOC requirements have been met.
4.8.4. All items marked as exceptions during the PSSR shall have further action required, and
shall be tracked to completion.
All Pre-Startup action items shall be completed prior to start-up of the change.
All Post-Startup action items shall be completed within 90 days from the date of
approval for start-up.
4.9. APPROVAL FOR START-UP
4.9.1. The Superintendent or Section Head of the unit/area where the change is taking place
shall provide approval for start-up of the change after ensuring the following:
All PSSR Pre-Startup action items are complete and,
All other MOC-related items have been resolved.
4.10. POST-STARTUP ACTION TRACKING
4.10.1. The PSM Group shall review the MOC for post-startup action items and upload these
into Action Tracker.
4.11. DOCUMENT UPDATE
4.11.1. The RIM group shall ensure the following:
Temporary (redline) document updates are loaded into EDMS within 30 days from
approval of start-up; and,
Final document updates are completed within 90 days from approval of start-up.

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4.12. MOC CLOSURE


4.12.1. All post-startup action items, including final document updates, shall be completed
within 90 days from the date of approval for startup.
4.12.2. MOC closure shall be completed when all post-startup items are closed.
4.12.3. The Technical Manager or his/her designee shall review and approve closure of the
MOC.
4.12.4. If an MOC was designated as High Risk, the change shall be reviewed and inspected
between six months and one year following its closure to ensure that the change is
performing as desired.
This exercise shall not be included in the closeout process for the MOC. At the
end of the follow-up period, the Process Safety and Compliance Group shall
review the change with the area owners and other affected stakeholders to
evaluate the path forward.
4.13. TEMPORARY MOC
4.13.1. Temporary MOCs shall only be valid for 90 days from the date of approval for startup.
4.13.2. Before the Temporary MOC expiration date is reached, the change must be assessed
for the appropriate path forward. The originating group, and if applicable, area/unit
owner superintendents shall grant approval of the selected action as listed below:
Revert the change is reversed, all equipment and conditions restored to what
they were prior to the change;
Convert the change is made into a Permanent MOC;
Extend the change needs to remain in place beyond 90 days. Authorization
shall be obtained for the extension through a Safety Variance.
4.13.3. A PSSR shall be performed prior to reverting a change back to its original state, or
converting it to a permanent MOC.
Representation on the PSSR team shall be the same as the initial PSSR.
4.14. EMERGENCY MOC
4.14.1. The following questions must be answered by the initiator to prove the validity of an
Emergency MOC:
Is the change required immediately to avoid personnel injury, equipment damage,
severe economic impact, environmental impact, or community impact?
(Appropriate Response: YES)
Can the proposed change compromise safety and health? (Appropriate
Response: NO)
If the appropriate responses to these questions are not met, then an Emergency
MOC is not necessary, and a Permanent or Temporary MOC shall be required for the
change.
4.14.2. The facilitator shall conduct a Hazard Analysis with available expertise as per the
guidelines of Section 4.5.

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The facilitator shall use the call-out list during off-hours or holidays.

4.14.3. The facilitator shall contact the Unit/Area Superintendent and superintendents of other
affected areas to discuss the emergency change and results of the hazard analysis
prior to requesting approval to implement.
4.14.4. Prior to start-up, a PSSR shall be completed with available expertise as per the
guidelines of Section 4.8.
4.14.5. The Shift Coordinator/ Shift Supervisor (RLOC) shall take the place of the Unit/Area
Superintendent in signing off the necessary steps in the MOC process.
4.14.6. The facilitator shall use the hard copy MOC form to document the emergency change.
4.14.7. Beginning on the next regular workday, the Emergency MOC shall be uploaded into the
electronic MOC application and shall go through the normal review process for a
Permanent or Temporary MOC.
4.15. SHUTDOWN MOC
4.15.1. Changes that are intended to last until the next shutdown, such as pipe clamps and
other temporary leak repairs, shall be managed through permanent MOCs.
4.15.2. Two permanent MOCs are required for these changes. The first MOC is to document
the installation of the change and the second MOC is for restoring it back to its original
condition.
4.15.3. The first MOC shall require the development of a documented monitoring plan relative
to the risk associated with the change as determined during the Hazard Analysis and
MOC Committee Review.
The plan shall be periodically updated until the equipment/system is restored
back to its original condition.

5.

TRAINING
5.1. Training shall be provided to all affected personnel based on the frequency specified in the
Global Training Matrix.

6.

RECORDKEEPING
6.1. MOC-related documentation shall be maintained as per the Records and Information
Management Policy and the Records and Document Retention Policy.

7.

SYSTEM PERFORMANCE ASSESSMENT


7.1. Facility MOC data shall be reported and evaluated through the PSM Metrics.
7.2. Compliance with MOC requirements shall be audited and reviewed through the PSM SelfAudit and OE Self-Review processes.
7.3. This procedure, along with its associated work processes, will be reviewed at 3-yr intervals
unless circumstances necessitate a review within a shorter time frame.

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RESPONSIBILITIES
8.1. Process Safety and Compliance Group

Owner of the MOC work process

Administers the MOC application in coordination with the IT Department


8.2. Technical Department

Owner of EDMS

Maintains PSI and non-PSI documentation


8.3. IT Department

Provides technical support for the operation and/or maintenance of the MOC
application

9.

ATTACHMENTS
9.1. Change Request Form
9.2. MOC Form
9.3. Basic PSSR Form
9.4. Comprehensive PSSR Form
9.5. MOC Hazard Evaluation Form Environmental Group
9.6. MOC Hazard Evaluation Form Technical I&E Group
9.7. MOC Hazard Evaluation Form Engineering Group
9.8. MOC Hazard Evaluation Form Equipment Reliability Group
9.9. MOC Hazard Evaluation Form Maintenance I&E Group
9.10. MOC Hazard Evaluation Form Maintenance Mechanical Group
9.11. MOC Hazard Evaluation Form Production Group
9.12. MOC Hazard Evaluation Form Personnel Safety Group
9.13. MOC Hazard Evaluation Form Process Safety Group
9.14. MOC Hazard Evaluation Form Industrial Hygiene Group
9.15. MOC Hazard Evaluation Form Emergency Response Group
9.16. MOC Hazard Evaluation Form Security Group
9.17. MOC Hazard Evaluation Form Laboratory Group
9.18. MOC Hazard Evaluation Form Blank Template
9.19. QC-PSM-SFM-00-0010 Equipment Integrity,Deviation from Standard/Approved Practice
Form
9.20. QC-PSM-GLN-00-0001 MOC Requirement Guidelines and Examples
9.21. Management of Change (MOC) Work Flow

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10. REFERENCES
10.1. 29 CFR 1910.119 OSHA Process Safety Management (PSM) of Highly Hazardous
Chemicals
10.2. EHS-1100 Operational Excellence (OE) System Manual
10.3. EHS-6185 Global OE Procedure on Management of Change

11. APPENDICES
11.1. MOC Application User Manual
11.2. Pre-Proposal Questionnaire
11.3. Risk Level Determination

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APPENDIX 11.1 MOC Application User Manual


(Placeholder - to be added when the application is completed)

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APPENDIX 11.2 Pre-Proposal Questionnaire


If YES is answered to any of the following questions, an MOC shall be generated unless an
equivalent approved alternate process to manage the change is in place.
1. Will this change feedstocks, chemicals, or catalyst composition, use, or conditions?
2. Will this change cause the use of different process conditions, instrumentation, and process
control or affect upstream or downstream plants?
3. Will the change result in operation outside of established PSI (safe upper and lower limits)?
4. Will this change cause the use of new or modified equipment, piping, control systems, all onstream leak repairs, clamps, hot taps, stopples, relief valve additions, P&ID updates, or changes
to facility safety equipment, PSI, etc. (which is not RIK)?
5. Will this change cause the modification of existing or addition of new operating and/or
maintenance procedures (except where the change only involves the procedure itself)?
6. Will this involve changes to permanent or temporary buildings including renovations and fire
protection, temporary placement of a structure within a facility, or changes to any roads?
7. Will this change affect the security of the site?
8. Will the change increase the potential for dust explosions or affect dust explosion protection
equipment?
9. Will the change affect personnel fatigue?

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APPENDIX 11.3 Risk Level Determination


Degree of Hazard (Two or more YES answers constitute a HIGH degree)
1. Does the change introduce a significant source of potential chemical, mechanical, thermal,
nuclear, or electrical energy?
2. Does the change result in any increase in inventory or flow rate of toxic, flammable, or reactive
materials?
3. Will the changed process/system contain any material known or suspected to be thermally,
chemically, or physically unstable?
4. Does the change significantly increase the potential for personnel exposure to a hazardous
material?
5. Does the change significantly increase the potential to adversely affect the public and/or the
environment?
Significance of Proposed Change (Two or more YES answers constitute a HIGH significance)
1. Could the change cause the process or system to operate outside safe upper or lower operating
limits as defined by operating procedures, equipment datasheets, or other process safety
information during steady state or transient conditions?
2. Does the change reorder or alter the process sequence?
3. Does the change impact the throughput of the unit?
4. Is the change complex?
a. Complex Examples include, but are not limited to, installing / modifying / deleting of
process equipment, process control loops, re-rating of safety equipment, safety
instrumented systems, etc.
b. Simple Examples include, but are not limited to, new pressure gauge, changing an
alarm point, adding a bleeder, etc.
5. Does this change require substantial operator interface needed for normal and/or emergency
operation of the existing system?

Risk Level Matrix

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HIGH

LOW RISK

MEDIUM
RISK

MEDIUM
RISK

HIGH RISK

LOW

LOW

HIGH

DEGREE OF HAZARD

SIGNIFICANCE OF CHANGE

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