Revision: 38
By: E. Cruz-Diaz
Verified by:___
Date:______/ MANAGEMENT OF CHANGE (MOC)
Date Reviewed:
07/02/15
/ I-A-09.00 Page 1 of 9 / Original Issue: 04/23/92Originator: D. Jarisch
1.0 PURPOSE AND SCOPE
1.1 Purpose
Management of Change (MOC) is a review and authorization process for evaluating proposed adjustments to Green Lake’s facility design, operations, organization or activities prior to implementation in order to insure risks to employees, public and environment arising from the proposed changes are managed to eliminate or reduce them to an appropriate level. MOC is not implemented for replacement-in-kind (RIK) changes. RIK is defined as any change that uses the same size, material, style, type, range, chemicals, control, operation and/or procedure. The MOC process must also communicate appropriate details of a change to impacted personnel.
· Technical – any physical change or deviation from documented safe operating limits, except replacement-in-kind;
· Administrative – any deviation / variance from the approved work procedures or regulatory approvals;
· Organizational / personnel – any change in the organization or in personnel with specific knowledge or experience who supervise, operate or affect the safe operation of Green Lake during both normal and emergency situations.
· Product quality – any changes which may impact product quality and customer’s processes
1.2 Scope
This MOC process will be applied to temporary and permanent changes to technology, organizations, staffing levels, procedures, equipment, product quality, raw materials, quality changes but not a RIK at the Green Lake facility, Port and pipeline. The duration of these changes can be as follows:
· Permanent
· Temporary – Temporary MOCs are provided for a defined time period. These time limits and any other stipulations of the temporary change shall be monitored and are not to be violated. Temporary changes may be made to operating conditions through shift instructions, but must include an expiration date. The choices for the final disposition of a temporary MOC include;
o Returning change to its original condition,
o Converting the change to a permanent MOC, or
o Extending the temporary change (30, 60 or 90 days).
· Emergency – any action necessary to remedy an emergency that poses imminent impact to safety, health, or the environment and demanding an immediate response. Emergency changes are permitted only on the verbal authority of the appropriate Green Lake management team member(s) following an appropriate hazards assessment, and every effort should also be made to complete an appropriate cross discipline review. An authorized MOC must be completed as early as possible after the emergency situation has subsided. Normally no later than the next day.
I-A-09.00 SOSO Page 9 of 9
Rev. #: 38
2.0 KEY RESPONSIBILITIES
The following roles and responsibilities are to be used as a recommended guideline. Each responsible party listed below must understand the definition of change and understand the Green Lake process to ensure changes are managed to eliminate or reduce risks associated with a change to an appropriate level.
2.1 Initiator
The Initiator’s role in the execution of an MOC includes;
· Initiating, as appropriate, process changes, procedural changes, or other issues requiring an MOC;
· Providing as much information as possible regarding a proposed change to the MOC Coordinator, including items such as identification of the affected drawings, a description and possibly the scope and justification, and any comments or concerns associated with the change; and
· Participating, as required, in any activities supporting the MOC process, such as hazards assessments, training, etc.
2.2 MOC Coordinator
The Coordinator’s role in executing the MOC program includes;
· Managing the MOC process to assure conformance with the procedure,
· Leading the MOC Review Team
· Maintain an updated index for all Mod A’s, B’s, C’s and D’s.
· Entering all completed tasks within SAP
· Releasing notification to maintenance for field construction
· Closing out the MOC.
· Following-up on the disposition of temporary MOC’s, and
· Auditing the MOC process to insure conformance
2.3 MOC Review Team Members (MOCRT)
The review team members have a significant role in executing the site’s management of change (MOC) program. The Review Team Members are selected and assigned to the team by the site Leadership Team. The SHE Mgr will ensure the selection process is consistently executed. They are made up of a cross discipline team of SHE, Production, Plant Services, Engineering and I&E. They must:
· Be knowledgeable, trained and experienced with the equipment, practices, and process changes under consideration; and
· Document the necessary hazard assessments (review levels) and training for the change
· Nominate the appropriate personnel to lead review (project/engineering lead)
· Nominate the approvers for the change
· Avoid Engineering solutions
2.4 Review Leader
The Review Leader is responsible for:
· Preparing a detailed scope of work to be performed
· Presenting the technical basis and design for the proposed change
· Modifications to process safety information (PSI)
o P&IDs
o Procedures
o Organizational charts
o MSDS
o Critical instrument/equipment lists
o Engineering studies
o Design calculations
o Process chemistry changes
o Safe upper/lower limits
· Determine training needs
PROCESS FOR DETERMINING LEVEL OF TRAINING
Formal Training is required for:
· A new procedure
· An action item from a Full Committee Investigation that requires training
· Modifications to processes, piping, or systems that result in changes to
o Physical control points such as valve realignment, new tie-ins, additional valves
o Process controls not included in temporary shift instructions
o Upper and lower safe limits
o Procedure step order when not associated with a checklist
Procedure Reviews can be used for:
· Minor changes to procedure step order when not associated with a checklist
· Clarification on procedure tasks including recommended controls and loss exposures
All scenarios cannot be predicted. When in doubt, consult with the Training Coordinator.
· Safety considerations and risk analysis
· Completing checklists found in this procedure
· Supporting documentation (calcs., phone conversations, vendor quotes, etc)
· Obtaining appropriate approvals or rejections.
2.5 Approvers
The Approvers must document and formally acknowledge their acceptance or rejection with the technical, administrative, organizational, operational, SHE and regulatory aspects of the proposed change. With their acceptance, approvers are noting that they have considered the hazards associated with the change and the proposed methods to manage those hazards and consider them adequate. Production Manager has final approval for execution of Mod A.
3.0 PROCESS FOR CATEGORY “A” MODIFICATIONS
Physical changes to design, operations or activities which are not replacement-in-kind (RIK) are addressed with Category A Modifications. This may be either expense or capital projects.
The Category A procedure is triggered by a Notification in SAP.
The Initiator of the Notification must record the details of the modifications in the Notification including the date for removal of the modification if it is temporary. The temporary change must be removed by this date or sent back to the MOCRT for review. The MOC coordinator documents this on the Notification Task List screen in SAP.
The Notification is then reviewed by the owner of the cost center to determine if it goes to MOCRT or if it is killed.
Capital Project related Notifications will be sent to MOCRT for review at the end of the Select Stage.
The Notifications are reviewed weekly by the MOCRT for determination of review level and determine if the change can be considered a preventive action, if so the code (9999) will be added to the notification. The Mod A review is broken down into three phases: Authorization, Pre-Startup Safety Review (PSSR when needed), and closure. The MOCRT will determine which phases are required for each project and the sign off requirements for each. A PSSR is required for new or modified facilities when change is significant enough to change Process Safety Information (PSI). Pre-Startup Safety Review walk-through at minimum, will consist of three people. The MOD A number is the same as the Notification Number.
The MOCRT assigns a Review Leader to complete the appropriate task. The MOC Coordinator will then email the designated Review Leader.
3.1 The Review Leader assembles the pertinent checklists. Checklists are found in SOSO I-A-09.02
a. Authorization Checklist
i. Notification number, project owner and project title are included.
ii. Detailed scope of changes MUST accompany MOD A paperwork. Include technical and design basis along with risk review.
iii. Implement appropriate review level.
1. Checklists only – Reserved for smaller equipment changes. (i.e. valve changes, instrumentation technology changes, etc.)
2. Checklists and What if – Reserved for temporary changes. (i.e. new chemistry, rate changes, reactor operational changes, etc.)
3. Checklists and HAZOP (Hazard and operability study) – required on any new process or grassroots development, anything that may affect the PHA for that unit.
4. Checklists and PHSR – major modification to existing units (>$5million) or significant changes to unit operability affected by project.
iv. Select appropriate checklists and ensure use of current version of SOSO I-A-09.02
v. To satisfy Process Safety Management (PSM) law, the scope MUST include input from an area leader.
vi. Review Leader must identify key PSM risk associated with the change. In other words, what can go wrong if project is not properly implemented.
vii. Review Leader must also identify all process safety information impacts.
b. CAD
i. Submit P&ID’s to CAD for changes and CAD request number
ii. Ensure most current drawing number/revision is used to annotate changes
c. Environmental
i. Note any increase in liquid, solid or vapour releases
ii. Determine if permits need modification
iii. Determine volatile organic compound (VOC) service
d. Maintenance
i. Think about equipment needed to complete the project. Logistics of crane entry, personnel and other requirements.
ii. Determine I&E involvement:
1. critical instrument list updates
2. other requirements
iii. Rotating equipment
1. specifications or new requirements
2. records updating
iv. Mechanical Integrity Specialist
1. inspection schedules
2. materials of construction
e. Process Engineering
i. Review of engineering specifications
1. address ASME, API and other industry standards compliance
ii. verify process condition changes
iii. control systems
f. Operations
i. Procedure updates
ii. Training
iii. Employee communication of changes
g. Quality
i. Process chemistry changes
ii. Addition/omission of process steps (i.e. filtration)
iii. Customer effects: positive/negative
h. Safety
i. Address employee exposure
ii. MSDS additions
iii. Noise levels
iv. ERT considerations
v. Escape routes
vi. Ergonomics
i. Pre-Start up safety checklist
i. Complete requirements from checklists. Does scope description match field installation
ii. Training completed and modified procedures implemented
iii. Complete punch-lists
j. Closure Checklist
i. Ensure all requirements from checklists, PSSR and hazard reviews complete
ii. Stores requirement for new equipment
iii. Industrial hygiene addressed – if applicable.
3.2 Present MOD A for review to each department. Note any suggestions and determine applicability to the current project scope. Include scope modification if necessary. The Review Leader will identify and capture all action items for each of the checklists and assign responsible parties and completion target dates. The MOC Coordinator will enter all action items in Traction to follow-up completion.
3.2.1 Any changes to the scope require buy in from all departments determined in the initial MOCRT review.
3.2.2 Simply create an addendum to original scope and supply a place for reviewers to sign and make comments.
3.3 Submit completed MOD A checklists to MOC coordinator for completion. Present MOC coordinator with copy of scope, red lined P&IDs and other pertinent information. Retain the original copies (with signatures) of the checklists. MOC Coordinator releases notification to maintenance for field completion by closing each task on SAP. Release of Notification will be granted only when all tasks are completed on SAP.
Capital project notifications and maintenance notifications have a similar work flow. The exception is for a capital project notification a PO number is already assigned prior the MOC coordinator releasing the notification. However no field work is allowed until all MOC Task Notifications are completed.
3.4 PSSR completion required prior to commissioning and operation.
3.5 Punch list items found on PSSR walk through completed prior to commissioning and operation
3.6 Upon completion of training, issuance of updated procedures and other PSSR requirements, place equipment in service.
3.7 Submit completed closure checklist, PSSR and applicable punch-lists to MOC coordinator for notification completion.
3.8 MOC Coordinator maintains and tracks completion of PSSRs punch list items by having an additional file with the items and sending follow-up via email to project/change owners.
3.9 Close out notification in SAP. Only after all PSSRs punch list items are completed, the MOC Coordinator will close PSSR task on SAP.
3.10 MOC coordinator retains all original copies of notification for the life of the process.
4.0 PROCESS FOR CATEGORY “B” MODIFICATIONS
A Document Amendment form shall be completed for any new, reactivated or change to an existing procedure or form covered by this SOSO. Upon completion in the computerized version (Mod B icon in the Green Lake Complex Applications folder), the modification number will auto generate. (Contact Administrative Assistant)
This does not apply for procedure reviews where no changes to the document are identified. For such cases, the document review date will be updated and only the coversheet re-issued. No changes will be made to the document revision number or date.
The Area Authority responsible for that area of plant control will present the document amendment form to the MOCRT after having reviewed, approved and signed the modification (“Responsible Authority Approval”). The field entitled “Description of Change to Procedure” must include both what the changes are and why they were needed.
If the area authorities determine the change does not affect the physical scope of the task, (e.g. it is only a change in wording or format) then the change may be approved with only their signature and need not be brought to the MOCRT for review. The completed Document Amendment Form document shall be sent to the MOC Coordinator.
For any procedural change brought to the MOCRT, the signature requirements for modification to the operating parameters will be determined by the MOCRT.