Management of Change (MOC) is a best practice used to ensure that safety, health, and environmental risks and hazards are properly controlled when an organization makes changes to their facilities, operations, or personnel. Having a properly implemented MOC policy in place when implementing changes can help ensure that new hazards aren’t introduced and the risk levels of existing hazards aren't being increased. Inadequate MOC on the other hand has the potential to increase risks to the health and safety of employees and the environment.
Effective MOC involves review of all significant changes to ensure that an acceptable level of safety will be maintained after the change has been implemented. From this evaluation, the proposed change can either be set for implementation, amended to make it more safe, or rejected entirely. Should the change be implemented, personnel should be informed about the change and how to maintain a safe workspace in this new environment.
Under the Occupational Safety and Health Administration’s (OSHA's) Process Safety Management (PSM) standard, performing MOC is required when making changes that could affect the safety of a facility. This can include changes in process chemicals, technology, equipment, procedures, and the number of employees involved in a process.
While MOC is generally used to examine the effects of a proposed permanent change to a facility, temporary changes should not be overlooked. A number of catastrophic events have occurred over the years due to temporary changes in operating conditions, staffing, etc. For this reason, an effective MOC program should address all changes that could affect the safety of a facility or personnel, regardless of whether or not it is permanent.
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September/October 2017 Inspectioneering Journal
By Daniel Cypriano at Petrobras, and Henrique Ventura at Petrobras
Although value-drivers often differ between facilities, all can agree that effective asset management strategies should lead to better decision making. In this case study, the authors detail how process-based risk management strategies can make for improved use of equipment. |
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Blog
September 13, 2017 By Jeremiah Wooten at Inspectioneering, LLC.
The U.S. Occupational Safety and Health Administration (OSHA) recently released a new guide to help petroleum refiners comply with its Process Safety Management (PSM) standard (1910.119). The guide presents lessons learned from the petroleum refinery Process Safety Management National Emphasis Program. |
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March/April 2017 Inspectioneering Journal
By A.C. Gysbers at The Equity Engineering Group, Inc.
Integrity Operating Windows (IOWs) have a subset of operating variables that are important for degradation monitoring, but may not have direct operational controls. Per API RP 584 Integrity Operating Windows, these are known as IOW Informational Limits, which are often neglected or misunderstood by operations or technical personnel within a plant. |
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January/February 2017 Inspectioneering Journal
By Israel D. Martinez at ORPIC
Evaluating remaining wall thickness of an asset is not enough to ensure its continued safe operation. Proactive strategies should be implemented to assess the entire environment affecting an asset’s condition, including the development of more effective inspection plans. |
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January/February 2017 Inspectioneering Journal
By Edwin A. Merrick, PE at The Augustus Group
This article presents a perspective on the human factor and emphasizes the value of using risk tools at all levels in the organization to help provide management focus during times of severe economic pressure. |
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May/June 2016 Inspectioneering Journal
By Jeffrey Foushee at Pinnacle Advanced Reliability Technologies, and Ryan Myers at PinnacleART
Data, in pure form, consists of raw, unorganized facts that need to be processed. Data can be found in databases, documents, drawings, reports, spreadsheets, and numerous other sources. Having data on hand is useful, however, it’s often inefficient and counterproductive to make decisions based on data in its raw form. |
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January/February 2016 Inspectioneering Journal
By Walt Sanford at PinnacleART, and Mauricio Olivares at Pinnacle ART
Equipment integrity and reliability programs are essential for refinery and chemical facility operators. The processes of the programs are developed to ensure safety, optimize component life cycles, and promote smooth and economical operations. |
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September/October 2015 Inspectioneering Journal
By Marc McConnell, P.E. at Pro-Surve Technical Services, and Nolan L. Miller at SASOL North America
If we could measure, understand, mitigate, and most importantly, control corrosion, we can do a better job of keeping the product in the pipes. To accomplish this task, we needed to know what is causing the corrosion and how to control it. |
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Blog
March 9, 2015 By John Reynolds at Intertek
Management of change (MOC) for fixed equipment mechanical integrity (FEMI) issues is one of the most important of the 101 essential elements in pressure... |
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November/December 2014 Inspectioneering Journal
By Scott Corey at Sentinel Integrity Solutions Inc.
One of the major challenges inspectors and plant operators face after each turnaround is to ensure that all repair and scope work is and was completed in accordance with the client’s requirements. Sometimes that verification will be to ensure work was completed in conjunction with the applicable codes, and sometimes that it was completed in conjunction with the client’s own in-house specifications. |
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Partner Content
Industrial Rope Access is a proven method of achieving a safe work position at elevated heights or areas that are difficult to access. When combined with advanced NDE technologies, rope access technicians can substantially reduce the cost of inspections and maintenance activities by virtually eliminating the need for fixed scaffolding. |
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September/October 2014 Inspectioneering Journal
By John Reynolds at Intertek
Based on my 45+ years of experience working with fixed equipment mechanical integrity (FEMI) issues in the refining and petrochemical processing industry, this article summarizes what I believe are the top 10 reasons why pressure vessels and piping systems continue to fail, thus causing significant process safety events (e.g. explosions, fires, toxic releases, environmental damage, etc.). |
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Blog
July 28, 2014 By John Reynolds at Intertek
Fixed equipment mechanical integrity (FEMI) failures are not caused by damage mechanisms; rather, they're caused due to failure to create, implement, and maintain adequate management systems to avoid failures. Nearly all failures that have occurred in our industry could have been avoided if these human systems were more robust and sustainable in providing the primary layers of protection for FEMI. |
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Blog
October 21, 2013 By John Reynolds at Intertek
As I stated in my previous post, there are 10 essential Management Systems (MSs) needed for an effective PEI program that can achieve excellence. These 10 PEI MSs contain all the necessary information that describe what needs to be accomplished, and how to accomplish it, in order to achieve success in PEI. |
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Blog
October 7, 2013 By John Reynolds at Intertek
Knowing what needs to be accomplished in order to achieve excellence in pressure equipment integrity (PEI) is one thing, but knowing how to organize it all for success is quite another. |
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Blog
September 23, 2013 By John Reynolds at Intertek
These posts came about because, from time to time, I’m asked why some operating sites don’t seem to pay adequate attention to the need to protect and preserve pressure equipment integrity (PEI). Too often a few sites don’t seem to “get it” until they have a major process safety event associated with a failure of pressure equipment. When that happens, they are suddenly on... |
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Partner Content
InVista is a lightweight, hand-held ultrasonic in-line inspection tool (intelligent pig) capable of detecting pipeline wall loss and corrosion in unpiggable or difficult-to-inspect pipelines. The pipeline geometry inspection data captured by the InVista tool is exceptionally powerful when combined with the LifeQuest™ Pipeline fitness-for-service capabilities, providing an integrated solution set for the pipeline industry. |
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Blog
July 22, 2013 By John Reynolds at Intertek
Without doubt management needs to ensure that the appropriate resources (human and budgetary) need to be provided for corrosion control and prevention. The C/M engineer/specialist or other responsible party needs to assure that management is advised annually at the appropriate time what resources will be needed for the next budget cycle. |
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July/August 2013 Inspectioneering Journal
By Marc McConnell, P.E. at Pro-Surve Technical Services
Who at your facility “owns” injection point hardware? Typically, injection point hardware falls into the “Gray Zone”. |
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March/April 2013 Inspectioneering Journal
By Hearl E. Mead Jr. at Shell Oil Company
Over the past few years increased feedstock flexibility has become a growing reality for sustainability of the refining business, requiring processing of more difficult crudes, increased volumes of spot cargoes, and rapid response to crude acceptance requests. Equipment reliability and process safety threats have occurred in the industry from changes in crude supplies or varying crude blends and quality. |
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November/December 2010 Inspectioneering Journal
By John Reynolds at Intertek
High Temperature Hydrogen Attack (HTHA) is a long known and still occurring degradation issue for fixed equipment construction materials in the hydrocarbon process industry where hydroprocess plants (hydrogen plus hydrocarbons) are in service. Though HTHA failures in these units are the focus of this article, it is important to recognize that HTHA damage can also occur in high pressure boiler tubes, hydrogen producing units, synthetic gas units, ammonia plants and other equipment where hydrocarbons may not be involved but high temperatures are involved. |
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March/April 2010 Inspectioneering Journal
By John Reynolds at Intertek
This article in the series will focus on two more of the necessary MSs for achieving excellence in PEI: Integrity Operating Windows (IOWs) and Management of Change (MOC). |
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July/August 2004 Inspectioneering Journal
By John Reynolds at Intertek
High temperature oxidation is not a real common type of failure in our industry, but it can and does happen when temperatures exceed design maximums. All metals oxidize, even at room temperature, and in many cases that slow oxidation process actually protects the metal from rapid oxidation. |
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July/August 2004 Inspectioneering Journal
By John Reynolds at Intertek
High temperature sulfidation is probably the most common high temperature corrosion nemesis in the refining industry, since there are very few “sweet” refineries still in operation. Sulfidation corrosion typically is of concern in sour oil services starting at temperatures in the 500F (260C) range. |
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May/June 2000 Inspectioneering Journal
By John Reynolds at Intertek
This is the first of a series of articles that outlines the 101 essential elements that need to be in place, and functioning well, to preserve and protect the reliability and integrity of pressure equipment (vessels, exchangers, furnaces, boilers, piping, tanks, relief systems) in the refining and petrochemical industry. |
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May/June 1997 Inspectioneering Journal
By John Reynolds at Intertek
In the Jan/Feb issue of the IJ, I mentioned how important the Management of Change (MOC) process is when it comes to maintaining safe, leak-free piping systems; stating that we in the inspection business cannot do it alone; that is, we taint the integrity of piping systems without a lot of help from operating personnel and operations support engineers. |
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January/February 1997 Inspectioneering Journal
By John Reynolds at Intertek
It's probably more important to those of us who don't have a brain tumor. Unfortunately, it's precisely because piping inspection is not neurosurgery that it's often done poorly, which can lead to significant impacts on process unit reliability, or worse, a catastrophic event, where people can get hurt. |
The U.S. Chemical Safety Board (CSB) has released a safety video detailing its investigation of the June 13, 2013 explosion and fire at the Williams Olefins Plant in Geismar, Louisiana, which killed two workers and injured an additional 167.
