Professional Documents
Culture Documents
MANAGEMENT OF CHANGE/PRE-START
UP SAFETY REVIEW
QC-PSM-PRO-00-0003
Rev. 0.1
20-Jan-2013
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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.
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
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Prepared
By
Reviewed
By
Roehl
Bartolome
Carl Poldrack
Roehl
Bartolome
Carl/Venkat
Approved
By
Plant
Management
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:
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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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:
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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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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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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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.
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UP SAFETY REVIEW
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RESPONSIBILITIES
8.1. Process Safety and Compliance Group
Owner of EDMS
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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QC-PSM-PRO-00-0003
HIGH
LOW RISK
MEDIUM
RISK
MEDIUM
RISK
HIGH RISK
LOW
LOW
HIGH
DEGREE OF HAZARD
SIGNIFICANCE OF CHANGE
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