If you’re involved in building and maintaining facilities, particularly those that handle hazardous materials and deal with Management of Change (MOC) processes, you know how important it is to comply with all the safety and environmental regulations that come with designing every change within your facility. MOC is a big deal and it is one of the more difficult processes in a plant in terms of downtime, outages, resource, and risks regarding exposure to fines, lawsuits and negative publicity. Risks like these can increase as activities and man-hours increase and generations of knowledgeable employees retire.
MOC has received more attention at chemical plants and refineries over the past several years due to the increase in new OSHA regulations. Officially designated 29CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals, OSHA PSM regulations state that any time a critical component in an oil or chemical plant changes, a formal MOC program is required to ensure that the proposed change is made safely.
But according to an article published in Maintenance Technology magazine Dr. Rainer Hoff, President of Gateway Consulting Group, says that while plant owners are in compliance with OSHA regulations, their MOC processes are not necessarily efficient. Dr. Hoff analyzed MOC processes at over a dozen chemical and petrochemical facilities in the U.S. and says evidence of poor efficiency includes:
• long cycle times for MOC closure;
• the need for, and hiring of temporary staff to “look after the MOC paperwork” prior
to and during turnarounds;
• people being asked to review documents that they’ve signed-off previously;
• any person who is asked to sign a document or form, to signify that they’ve been
notified rather than to approve the document.
Dr. Hoff says to excel at MOCs, organizations need an ECM system with an MOC application. The system should have a repository for managing all the plant documentation including drawings and equipment files; a records management function to ensure that all data in the repository is compliant with applicable regulations and standards; an MOC application that manages all the data needed to execute the MOC; and an electronic signature capability.
In his whitepaper: Management of Change Best Practices Dr. Hoff offers solutions for MOC best practices, eliminating bottlenecks and identifying areas for improvements that provide facilities with real business benefits and savings. He also spoke about his research in a podcast we recorded this week.
To learn more, we’ve set up an information page that provides details about how you can streamline your MOC processes.
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