Management of Change (MoC) is a major element of Process Safety Management Systems and was identified as a key failure in the Texas City disaster of 2005.
In high hazard environments, process, management and organisational changes regularly occur. Even the most minor variation can have significant effects on existing control barriers or introduce new hazards.
At the Texas City refinery, an MoC was required for all changes except those of organisational nature, such as budget cuts.
When this occurred, this introduced the hazard of of cutting back on the mechanical integrity programme. To compound this, 20% of the actions they had identified from other MoC were overdue although key changes had been made before and even without, final MoC approval,
The Institution of Chemical Engineers (IChemE) recommendations for effective MoC include:
❗ Anything that is not a like-for-like replacement must be assessed.
❗MOCs must be regularly reviewed to ensure that MOCs are assessed and actions progressed.
❗Leading and lagging KPIs must be used to assess MOC effectiveness.
❗Temporary changes must be included and should be periodically reviewed and reassessed for continuation.
❗Changes must be reviewed, peer-reviewed and authorised before being implemented.
We take a risk based approach to MoC which aligns to the scale, scope and complexity of the process under consideration.
When we develop Process Safety Management Systems for our clients, we embed practicable metrics to measure the performance of the system as we recognise that the most robust procedure is only as powerful as the level of buy in and safety leadership within the organisation.
