Managing the risk of MOC

Abstract

AbstractDuring the execution of a change using Management of Change (MOC), the risk to the facility is increased because things are in flux until the change is completed and documented and personnel trained. During this time P&IDs, SOPs, and other procedures are being developed or changed. Construction or tie‐ins in preparation, or as part of the change, are going on. Thus, during the change until it is complete, the potential for error, and therefore the risk, is increased. This potential for error emanates from the use of not‐yet implemented P&IDs, the use of unapproved or old procedures, and unintended connections and flows from or to piping that contains hazardous materials. Additional risk results from an incorrect workflow where the appropriate individuals were not included in the review or the necessary approvals are bypassed. Another possible risk is unknowingly impacting an existing safeguard by changing related equipment. Thus, the MOC process needs to be carefully managed, not only for an individual MOC but the aggregate of all the MOCs that are being worked on at the same time. The elements for minimizing the risk of a change are described, and a tool to monitor the MOC process, which includes automatic metrics, is illustrated.