Course Material 1. 2. 3. 4. 5. 6. 7. 8. 9. Overview of Process Safety Compliance with Standards Process Hazard Analysis Standard Operating Procedures Safe Work Procedures Mechanical Integrity Management of Change Auditing Process Safety Systems Emergency Response Procedures Process Safety Management for Biofuels 7. Management of Change 29 CFR 1910.119 (l) This material was produced under grant SH-19479-09-60-F-36 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government. Flixborough Reactor Series Bellows at Flixborough Of Management of Change 1. System Design Definitions Management of change (MOC) A management system for ensuring that changes to processes are properly analyzed, documented, and communicated to affected personnel. Management of Change process chemicals, technology, equipment, procedures facilities Process Safety Information 1910.119(l)(4) If a change covered by this paragraph results in a change in the process safety information required by paragraph (d) of this section, such information shall be updated accordingly. Management of Change System Design 1. Written MOC procedures 2. MOC “owner” 3. Defined scope 4. Defined roles and responsibilities Management of Change System Design 5. Management of Change log 6. Management of Change form 7. Periodic monitoring (field checks) 8. Auditing Management of Change Training 2. The Management of Change (MOC) Process Replacement in Kind Actuated butterfly valves Butterfly valve Ball valve Gate valve Management of Change Training on the Change Management of Change 1. Technical basis 2. Impact on safety and health 3. Modifications to operating procedures 4. Necessary time period for the change 5. Authorizations 1. Technical Basis for Change What? How? Why? Where? When? 2. Impact on Safety & Health 3. Modifications to Operating Procedures 4. Necessary time period for the change Management of Change 5. Authorizations DEFINING ROLES AND RESPONSIBILITIES DEFINING ROLES AND RESPONSIBILITIES Change Originators ROLES AND RESPONSIBILITIES Reviewers ROLES AND RESPONSIBILITIES MOC Coordinator ROLES AND RESPONSIBILITIES PSM Manager ROLES AND RESPONSIBILITIES Employees ROLES AND RESPONSIBILITIES Senior Management Changes to cover under MOC 1. Capital improvement projects 2. Maintenance work orders 3. Instrument change requests 4. Spare parts control, warehousing, and distribution 5. Engineering change requests Changes to cover under MOC 6. Research and development (R&D) process change recommendations 7. Company specifications 8. DCS programming change requests 9. Process experiments or tests conducted in the manufacturing plant. 10. Contractor service agreements Guiding Principles for Implementation 1. Keep it simple 2. Obtain acceptance 3. Field test the system 4. Provide adequate training 3. Maintaining an effective Management of Change (MOC) Process Maintaining an MOC System 1.Monitor effectiveness 2. Audit 3. Demonstrate commitment Effectiveness of MOC System Key Performance Indicators 1. The number of MOCs performed each month. 2. The monthly percentage of work requests that are classified as a change. 3. The percentage of emergency MOCs. 4. The average backlog of MOCs. 5. The average calendar time from MOC origination to MOC authorization. Effectiveness of MOC System Auditing 1. Documentation completed 2. Training conducted 3. Procedures reviewed for updating 4. Pre-Startup Safety Reviews Management of Change Pre-Startup Safety Reviews Pre-Startup Safety Review The term pre-startup safety review (PSSR) means a final check prior to initiating the use of process equipment. PSSR It is applying a systematic method to confirm that the startup team and process equipment are prepared for startup. Definitions Trigger Event Any change being made to an existing process, or any new facility being added to an existing process or facility, or any other activity a facility designates as needing a pre-startup safety review. Non-change Trigger Event When Should a PSSR be Performed 1. Capital project approved 2. Changes to Operating Facilities occur 3. Temporary Changes (Flixborough) 4. Restart of an idled process Best Practices – PSSR 1. Regularly evaluating industry process safety related incident reports and how PSSR was potentially involved in the situation. Best Practices - PSSR 2. Using electronic databases for capturing past PSSR documentation. Best Practices - PSSR 3. Performing PSSRs on selected critical maintenance activities. Best Practices - PSSR 4. Involving many different workers in the PSSR process. Best Practices - PSSR 5. Selecting a PSSR team leader who is somewhat removed from the specific project involving the change. Best Practices - PSSR 6. Showing open management support for the importance of PSSR. Compiling and Using a PSSR Checklist Compiling and Using a PSSR Checklist The role of the PSSR program is to provide a second layer of protection around the management of change element. Compiling and Using a PSSR Checklist Depending upon the specific processes, materials, intermediates, and products involved, the PSSR checklist questions should be customized to match the facility. Remaining Course Material 1. 2. 3. 4. 5. 6. 7. 8. 9. Overview of Process Safety Compliance with standards Process Hazard Analysis Standard Operating Procedures Safe Work Procedures Mechanical Integrity Management of Change Auditing Process Safety systems Emergency response procedures
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