Management of Change (MOC) and Pre-Startup Safety Review (PSSR) processes are the most challenging elements of OSHA's Process Safety Management (PSM) standard, the EPA's Risk Management Program (RMP) rule and the U.S. Department of Interior's Bureau of Safety and Environmental Enforcement's Safety and Environmental Management Systems (SEMS). Although the PSM standard has been around since 1992 and the industry has been managing change for several decades, we can still get it wrong, sometimes with disastrous consequences.
Why do we need to manage change?
Change is a normal part of continuous improvement for any business, but uncontrolled or poorly managed change has resulted in some of the worst disasters in the chemical process, oil and gas, and refining businesses. A well-managed MOC process is one of the foundations of safe and profitable operations.
In the chemical process industry, we refer to two kinds of change. These are replacement in-kind and replacement notin- kind. Best practice workflows and smart checklists help identify in-kind and notin- kind change. All change must be managed, but one that is classified as not-inkind requires formal evaluation, approvals, PSSR, and Startup approval -- a more formal and careful approach. PSSR is a complimentary element or workflow designed to increase effectiveness and reduce the risk of change. More on that will be looked into later in this article.
How does automation help?
An automated best practice MOC and PSSR system helps ensure that once you get it right, you keep it right. In other words, you maintain the integrity of the plant. An automated MOC and PSSR system makes sure any change is appropriately identified, evaluated, approved and executed in a quality way. Using a visual workflow to navigate from evaluation, to approval to action in the MOC process, showing progress with check marks or color-coding and enabling steps only when preceding steps are satisfied, is a best practice.
An automated MOC/PSSR process can ensure that all important steps are accomplished in the intended manner. The process should change as a consequence of the change type -- piping, fabrication, operation, etc. -- as well. Smart checklists, based on the type or category of the change, can be presented to the users to ensure relevant questions are presented that assist with decision making and the completeness of the evaluation. In addition, email notifications should be used to alert persons assigned to manage, approve and execute actions along the workflow. Notifications can also bring attention to past due actions and escalate them to management.
PSSR is not actually part of the main MOC process. It is intended to be a redundant check or review to ensure that an MOC has been properly implemented. Leveraging automation helps here, too, by presenting appropriate PSSR checklists and questions at the end of the MOC process.
There are clear advantages to adopting and automating the best practice MOC and PSSR workflow. As your best practice evolves, so must the configuration of your MOC and PSSR solution. Refresher training of the solution administrators, upgrading the solutions features, constant tuning and tweaking of the workflow, checklists and notifications are all part of continuous improvement of an MOC and PSSR program. This minimal investment is a small price to pay to avoid poorly managed changes, increased risk or the opportunity cost of not collecting ideas from your idea initiators.
Words of caution
A cardinal sin of MOC and PSSR process automation is repurposing finance or maintenance technology to automate your best practice MOC and PSSR system just because you already have it. This misuse of technology will sub-optimize a best practice faster than anything you can do. Remember that 95 percent of your users are engineers, operators and managers. If the software does not make the work easier and more productive for them, they will not embrace it.
For more information, visit www.visiumkms.com or call (281) 617-4800.
