Promoting Safe Practices Through Management of Change

Sept. 5, 2012
Addressing challenges will better prepare operators for necessary change.

The Chemical, Petrochemical, and Refining Industries utilize some of the most dangerous materials in very capital-intensive processes.  The accidental release of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals can be catastrophic due to the human, financial and business costs of an incident.
The marcus evans 3rd Process Safety Management Conference for the Chemical, Petrochemical, & Refining Industries (Sept. 12 – 14, 2012,  Houston) promotes awareness on the evolution of risk mitigation and safety processes by providing practitioner-based case studies on the latest regulatory concerns and tools to improve PSM efforts including: Layers of Protection Analysis (LOPA), Management of Change (MOC), Process Hazard Analysis (PHA), and Mechanical Integrity.

There are several challenges process safety management (PSM) professionals face when implementing an MOC such as analyzing risk, recognizing change, and efficiently managing alterations.

Mike Whitten, process safety management coordinator at Koch Nitrogen Company, LLC, and speaker at the marcus evans event, answered a series of questions provided by marcus evans. The responses to these questions strictly reflect the views and beliefs of Mike Whitten and not necessarily those of Koch Nitrogen Company.

marcus evans (ME): In your opinion, what are the most prominent issues that should be covered when evaluating and recommending change?

Mike Whitten (MW): Truly understanding if the proposed change is not like-in-kind and having a clear technical basis and description of a change so that an adequate technical hazard review can be conducted.

In what ways can a company demonstrate conformance in control documents for MOC?

MW: Most MOC programs typically include some type of checklist to support the required technical /safety design reviews. This documentation in conjunction with any supporting documents derived from the technical review should be considered controlled documents that conform to the MOC requirements.

ME: What is the most effective way for changes to be communicated to employees before they become involved in operating the equipment/process changes?

MW: The most effective communication would be formal, face-to-face meetings; however, this is not practical in most cases. Some other options used have been making hard copies of all MOCs available in control rooms whereby operators have been required to review and sign [a document] acknowledging [their] understanding of the changes that have been made in their absence. Now with the advent of electronic MOCs, operators (an all affected personnel) may have easier and more effective access to the MOC information required to be reviewed prior to operating the process.  Some databases have the ability to time stamp when an operator opens and reviews the MOC records.  

ME: In what ways can a MOC process be initiated into an organization?

MW: From compliance with PSM perspective, it has always been effective to start with a review of the 1910.119(l) to ensure understanding of why there is a need for a MOC process. From there, providing training on the MOC procedure and working through examples of not like-in-kind changes should result in a fairly effective means of driving an MOC process into the organization.

The Pre-Conference Workshop A on Sept. 12 at 1:30 PM, prior to the marcus evans 3rd Process Safety Management Conference, will enable you to:
•    Evaluate current practices and procedures for MOC;
•    Demonstrate conformance to written programs to control and mitigate risk;
•    Focus on continuous improvement and assessment processes to ensure sustainable compliance.

For more information regarding this conference and to register, please visit or contact Robin Yegelwel at (312) 540-3000 ext. 6483 or [email protected]

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