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Management of Change (MOC)

&
Pre-Startup Safety & Environmental
Review (PSSER)

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TRAINING OBJECTIVE
• Review key concepts of Management of Change (MOC)
and Pre-Startup Safety & Environmental Review (PSSER)
• Why do Management of Change?
• Definition of change
• Types of change
• When is PSSER done?
• Why do PSSER?

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MANAGEMENT OF CHANGE
Management system to ensure:

• Proposed modifications are evaluated and controlled prior


to implementation
• New hazards are properly controlled
• Risk of existing processes are not unknowingly increased
• Site security is not compromised
• Proposed modifications are assessed for resource
conservation opportunities
• Changes are documented and site documentation is up-to-
date and reflects any changes

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MANAGEMENT OF CHANGE
Management system to ensure:

& &

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MANAGEMENT OF CHANGE
Requirements of a MOC program:

• Identify changes
• Review proposed changes for potential impact to safety,
health, environment, and site security
• Assess proposed changes for resource conservation
opportunities
• Evaluate engineering and administrative controls (proposed
and existing)
• Identify procedural changes
• Identify training requirements

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MANAGEMENT OF CHANGE
Requirements of a MOC program (continued):

• Reject proposed change or request additional information or


request additional controls be implemented
• Authorization to proceed
• Verify that the change has been constructed and installed in
accordance with design specifications (PSSER)
• Verify that recommended controls have been implemented
(PSSER)
• Update of plant documentation
• Close-out

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Definition of Scope of Site MOC
Site MOC procedure should define scope of the MOC
system including:

• Physical facility areas for which the MOC system applies


(Physical facility areas should include all areas where there
are chemical processes, or utility systems which support
chemical production.) – to be marked on a plot plan for the
site
• Phases of the process life cycle for which the MOC system
applies (Phases should include work prior to official
commissioning, operating lifetime, extended shutdowns, and
decommissioning.)
• Types of changes that will be evaluated using the MOC
system (See Examples of Changes in “Category” definition)
• Boundaries and intentional overlaps with other Process
Safety Management (PSM) elements
DEFINITION OF CHANGE
• Addition
• Modification (including operating equipment in a
deficient state)
• Deletion (including removal or taking equipment
out of service)
• Substitute for an item
• Not a replacement in kind

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DEFINITION OF
REPLACEMENT IN KIND
• An item (i.e., equipment, chemical, material,
procedure, organizational structure) that meets the
design specification, if one exists for the item it is
replacing.
• Identical replacement
• An alternative specifically provided for in the
design specification as long as there is no adverse
impact
• When in doubt MOC

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Plant Process Equipment Category
Examples of changes in this category that require MOC:
• substitution of equipment or alteration to equipment that is not
"replacement in kind" (For example: re-routing, size, pressure or
temperature rating, head, capacity and internals) - including rental
equipment
• additions or removal of equipment
• alterations of the materials of construction (For example:
equipment, seals and gaskets)
• addition, alteration, or deletion of a relief valve, rupture discs or
associated inlet or outlet piping
• addition, removal, bypass or revision to processing steps
• changes to ERCO standards & specifications for process
equipment
• changes to electrical classifications or replacement of
components with those having a lower classification
Plant Process Equipment Category (Cont’d)
• Changes to “Utilities” are included in this category.
• Examples for “Utilities” that require MOC if the change impacts
directly on a chemical process are:
o city water systems
o cooling water systems, including cooling water treatment
o plant water systems
o water deluge systems for chemical releases
o fire protection systems
o safety showers & eyewashes
o ventilation of process buildings & occupied buildings, such as
control rooms, which may be impacted by chemical releases
from processes
o heating & cooling systems only where required for corrosion
prevention, freeze protection or equipment cooling including
control room instrumentation
o sewer systems including effluent treatment
o process solid waste handling & temporary storage systems
Plant Process Equipment Category (Cont’d)
• Changes to “Utilities” subsystems are included in this
category.
• Examples for “Utilities” subsystems that require MOC if the
change impacts directly on a chemical process are:
o electrical utilities
o instrument power supplies & UPS systems
o emergency motor generator systems
o emergency lighting
o instrument air systems
o plant air systems
o nitrogen purge systems
o steam generation & distribution systems (including snuffing steam
for fire protection within equipment e.g., hydrogen vent stack,
boiler water & steam condensate systems)
o temporary use of rental equipment to replace failed utilities
equipment
Plant Process Equipment Category (Cont’d)
• Changes to “Facilities Infrastructure” are included in this
category.
• Examples for “Facilities Infrastructure” that require MOC if
the change impacts directly on a chemical process are:
o supports, foundations, other structures for process
equipment & piping
o floors, trenches & sump systems
o dykes & bund systems
o facility liner systems
o excavation
o road layout change
o process building structures
o construction activities that could impact the existing
operating plant including siting of construction trailers
Piping & Manual Valves Category
Example of changes in this category that require MOC:
• Re-routing and or re-sizing the process piping
• Changing material of construction for piping or manual valve that
are not mentioned in the corporate standards
• Changing the type or size of manual valve
• Using hoses temporary to handle chemicals (except when already
defined as a step within a written procedure)
• Adding a valve where there was none
• Repairing a service or process leak by banding or via an
engineered clamp requiring the injection of sealing compound
• Replacing steam heat tracing with electrical heat tracing
• Replacing a glass fiber reinforced PTFE gasket with an
unreinforced PTFE gasket
Instrumentation & Controls Category
Example of changes in this category that require MOC :
• addition, alteration, or deletion of safety devices or systems
• changes to electrical classifications or replacement of components
with those having a lower classification
• field hardware modifications that are not "replacement in kind"
• addition, alteration, or deletion of process control interface devices
• addition, alteration, or deletion of operator graphic interfaces
• addition, alteration, or deletion of operation control logic
• changes to the alarm points or interlocks that are outside safe
operating limits
• adding a new alarm (e.g. high temperature deviation alarm on a
reactor)
• changes to instrumentations that are not “replacement in kind”
• alterations of the materials of construction of instruments (final
elements)
• bypassing an interlock using the DCS system
Instrumentation & Controls Category
Example of changes in this category that require MOC:
• relocating a field signal from one input module to another.
• replacing a transmitter that produces an analog output with the one
that produces a digital output.
• replacing a vortex shedding flowmeter with a magnetic flowmeter.
• replacing the same module with an upgraded version with enhanced
diagnostics capabilities or one that provides new options for
responding to bad input signals.
Operating Procedure Category
Example of changes in this category that require MOC:
• Additions, deletions or revisions (excluding typographical corrections or clarifications)
to operating procedures
• Making Substantive formatting changes in the facility operating procedures
• Additions, deletions or revisions to defined safe operating limits
• Only additions, deletions or revisions which take the process outside of documented
safe operating limits or where safe limits have not been documented. (Changes to
operating parameters within existing <<operating procedures>> documented safe
limits do not require a MOC but do need to be managed according to ERCO Safety
Manual G.1 Operating Procedure Management)
• Alterations to process chemistry that will result in SOP changes
• Intended use of material received outside of specification
• Changes proposed by a PHA recommendation
• Changes to meet a new or revised regulation, code or ERCO standard. This is to
ensure that the change is studied for your site to ensure that any new hazards
created by the change will also be addressed to arrive at an overall lower risk level
Operating Procedure Category
Operating procedure changes that do not require
MOC:
• Typographical corrections
• Clarifications or explanatory information
• Description of safety and environmental considerations
• Description of safety systems and their function
• Reformatting an SOP
• Adding a step which is a current practice documented in a PHA
as a safeguard but which was missed from the SOP in error
does not require MOC documentation
Operating Procedure Category

Operating Limits exceptions – MOC not required:

Circumstance MOC not required for:

Any changes to alarms or


Safe limits are documented operating targets that do not
exceed the safe limits
Any changes to alarms or
Alarm points are documented operating targets that do not
exceed previous alarm points
Any changes to operating targets
Operating target or target range
that do not exceed the previous
is documented
operating target range
Mechanical Integrity Category
Example of changes in this category that require MOC
are:
• Maintenance procedure that require MOC are:
o additions, deletions or revisions to step in maintenance
procedures that are documented in step-by-step procedure
• Maintenance procedure changes that do not require
MOC:
o Typographical corrections
o Reformatting a procedure
o Clarifications or explanatory information
o Description of safety and environmental considerations
• change to any lubricants, grease used in gears and
bearing (not mentioned in the corporate standards
and specifications)
Mechanical Integrity Category
(Cont’d)
Example of changes in this category that require
MOC are:
• Increasing maintenance intervals based on the resource
constraints (consider past operating experience).
• Reassigning certain maintenance tasks from maintenance
personnel to operators (provide the operators with appropriate
procedures, tools, and training for the new responsibilities).
• Changing the inspection method for unit piping thickness from
ultrasonic to X-ray (consider the hazards associated with more
frequent ionizing radiation in the unit).
• Postponing a unit turnaround beyond the design run time limit,
resulting in exceeding the maximum allowable intervals for
certain equipment tests and inspections.
Mechanical Integrity Category
(Cont’d)
Example of changes in this category that require MOC:
• Deviating from documented ITPM plan (few examples below)
o Discontinuing certain ITPM tasks
o MOC system will be also used as management system for
documenting how equipment deficiencies were managed
o Decreasing the frequencies of inspections of equipments both
internally and or externally.
Raw Materials / Energy / Purchasing Services Category
• This category involves any change to purchasing of raw
materials, chemicals and/or services where the contract is
handled at the site level or Toronto Supply Chain
Department.
• Examples of changes in this category:
o alterations in supplier, manufacturer, manufacture location, grade or
specifications of Raw Materials, Energy Contracts, Water
Treatment Services, Waste Services, and Utilities.
o changing the type of defoamers used in cooling towers systems
o changing coolants for air compressors systems
o changing the vendor for fuel supplied for fire water systems
Product Distribution Category
• Changes in this category are issues managed by
Toronto Supply Chain Department (except raw
material, energy or services)
• Examples of changes in this category are:
o alterations to products such as chemical composition, physical
composition, specifications, shipping container, end use or
applications.
o changes to system used for tracking logistics
o adding new or changing transportation carriers, transportation
equipment, warehouses, distributors, terminals, packagers,
packaging, shipping documentation, network changes,
customer requirements, product swaps & purchases for re-sale /
regulatory requirements / product spec.
Organizational Change
affecting Responsible Care (RC) Category
Examples of changes in this category are:
• addition or reduction in number of personnel performing a
process operation or maintenance task
• change or reallocation of job functions affecting critical
supervision, controls, troubleshooting, or site emergency
response
• change in shift schedule effecting length and frequency of
exposure to chemicals
• change in job that results in greater number of tasks
• all of the above, even when it applies to a temporary
change
Non-Process Category
• Any changes at site that are not directly related to
chemical processes can be documented in this
category.
• Sites are not required to use this category. It is
used for sites who want a management system for
documenting changes made in other management
systems.
• Examples for changes in this category that would
initiate MOC:
o changes in the management systems like policies,
laboratory/analytical procedures and quality manual.
Is It a Change?
Examples:
• PED-2012-007
• VAL-2012-005
• GRP-2008-002
• TBB-2010-002
• VAN-2008-018

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Why Manage Change?
Poor Management of Change:
• ERCO examples
• Flixborough
• Bhopal (contributing factor)
• Chernobyl
• Motiva Delaware City Refinery
• Many others

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Why Manage Change?
• Improved safety performance
• Reduced liability
• Due diligence defense
• Better relations with the community
• Fewer environmental problems
• Lower risk of financial loss
• Improved operability

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Why Manage Change?

Outside Motivators
• Regulations
• Insurance companies
• Industry Associations (e.g., CIAC “Responsible
Care”, ACC, ASIQUIM)

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Why Manage Change?
Regulations
• OSHA 1910.119 Standard for Process Safety
Management of Highly Hazardous Chemicals
• EPA Risk Management Plan (RMP) rule
• Canadian Environmental Protection Act (CEPA)
Environmental Emergencies Regulations under
Section 200 (weak)

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TEMPORARY CHANGE

• Site MOC procedure should include procedures


for temporary change (including changes for
experimental testing)
• Time limit
• Identify who is responsible for monitoring
temporary changes
• Once time has expired – return to original
condition or new change request, not acceptable
to modify dates

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EMERGENCY CHANGE

A change that must be performed in a true emergency


because of any of the following conditions:
• Correct a deficiency that would cause a hazardous
condition
• Prevent an immediate environmental release
• Address impending external threats that could
result in a release, such as natural disasters
• Prevent a severe economic loss

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EMERGENCY CHANGE

• Site MOC procedure should include procedures


for fast tracking an emergency change
• Guidelines for when to use the emergency change
procedure
• Verbal approval from at least two qualified
personnel
• One should be the plant manager (or his
designate)
• Complete and authorize the change request
during the next normal working day.
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Pre-Startup Safety & Environmental
Review (PSSER)
Purpose:
• To ensure that new or modified processes are reviewed after
construction and before first startup on chemicals
• For changes to an existing facility, to assess the status of
MOC prior to startup on chemicals
• To ensure that recommendations of any PHA have been
resolved before startup
• To prevent chemical releases which result in health, safety,
or environmental impacts during startup or when operating
with the change in place

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Pre-Startup Safety & Environmental
Review (PSSER)
Scope:
• For an existing facility, all changes must be examined to
determine if a PSSER is required
• For a covered process, PSSER is required if there is a
change in process safety information
• For a non-covered process, PSSER is required if a change
to an existing facility required that a Process Hazard
Analysis be done to evaluate the change
• PSSER may also be done if the site personnel agree that it
would be beneficial
• For a new facility, a PSSER is required

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Why do PSSERs?
• Change is more likely to operate as intended
• Construction or maintenance work performed to build or
install the change meets the design specification originally
intended (e.g., errors are more likely for changes)
• Ensures that equipment is designed, fabricated, installed,
and operated in a manner appropriate for its intended
application (e.g., PHA recommendations are resolved)
• Operations, maintenance, and technical personnel are
trained in the change
• Procedures (safe work, operating, maintenance, and
emergency) are updated
• Process Safety Information is updated

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