Management of Change for facilities
Did you know that undocumented changes at facilities are a leading cause of safety incidents? This inculdes modifications to equipment, changes in operating setpoint, failure to update to procedures, failure to replace parts for like-for-like, and temporary workarounds that may seem minor on their own can introduce new hazard scenarios. They can also compromise existing safeguards or create combinations of conditions that were not addressed in the last HAZOP study. Unfortunately, it happens that is where River Energy Solutions come in.
Management of Change (MOC) is a process that ensures every change to a facility is properly reviewed. It ensures that any hazards are identified, that necessary documents are updated, and that staff receive training before the change occurs. According to OSHA Process Safety Management regulations, facilities that exceed certain limits must have a formal MOC program.
River Energy Solutions provides independent MOC review and facilitation for hydrogen facilities and facilities across North America. We bring direct process engineering and equipment engineering expertise to every change review — meaning we recognize hydrogen- or equipment-specific hazards that a generic process safety review will miss. We structure MOC documentation to satisfy OSHA PSM, insurance, and lender requirements.
What is a Management of Change(MOC)?
Management of Change is a process for reviewing proposed changes to a facility before they happen. The goal is to make sure that these changes do not unintentionally cause new hazards, weaken existing safety measures, or create situations that were not considered in the initial safety analysis.
OSHA PSM regulations (29 CFR 1910.119(l)) require facilities above the hydrogen threshold quantity of 10,000 pounds to maintain a written MOC procedure. The MOC should cover the technical basis for the change, safety and health impacts, modifications to operating procedures, time period for the change, and authorization requirements. MOC documentation must be completed before the change is implemented — not after.
The first — and most common — question in any MOC process is whether a proposed modification is a true Management of Change or a like-for-like replacement. A like-for-like replacement involves substituting identical equipment, materials, or procedures with no change to design intent, operating conditions, or safeguards. A true MOC involves any change that is not like-for-like — even if the change appears minor.
When working with facilities, it's important to be careful when replacing parts. Examples include: switching to a valve from a different manufacturer, using a gasket made from different materials, or choosing a pressure transmitter with a different range. These changes can create unexpected hazards and risks. These differences significantly affect the system's performance and safety. Changes such as these require a proper review and shall be done through the MOC process.
Why is Management of Change Important?
MOC holds significant value in enhancing safety and ensuring operational integrity. Changes in processes can present new hazards or intensify existing ones, which may lead to accidents or failures if not managed carefully. By embracing effective MOC practices, organizations can proactively identify potential risks early on, allowing them to implement necessary precautions that promote a safer working environment for everyone involved. This constructive approach not only mitigates risks but also encourages continuous improvement within the organization.
What is Involved in Management of Change?
To establish an effective Management of Change (MOC) process, it’s essential to approach it with a constructive mindset. Begin by thoroughly planning and documenting the proposed changes, ensuring a comprehensive risk assessment is conducted to identify any potential impacts. Engaging stakeholders early in the process is crucial; their insights and training will help foster a clear understanding of the change implications. Once the change is ready to be implemented, it should be executed with stringent controls and ongoing monitoring to assess its effects effectively. Finally, create a robust review process to evaluate the outcomes, allowing for valuable lessons learned to be integrated into future MOC initiatives.
How can River Energy Solutions help?
We offer valuable expertise to enhance your organization. By conducting a thorough assessment of your current MOC processes, we can identify areas for improvement or create a MOC process if one does not exist. We will collaborate with you to create a customized Management of Change (MOC) framework that supports your organizational goals and ensures compliance standards are met.