Management of Change
The objective of a Management of Change (MOC) program is to ensure all changes to a process are properly reviewed and hazards introduced by the change are identified, analyzed, and controlled prior to resuming operation. MOC often seems deceptively simple in concept but can be one of the most difficult elements of Process Safety Management to implement effectively.
Regulatory requirements for managing change are reviewed, including interpretations and clarifications that have been provided by OSHA since the PSM standard was issued OSHA 1910.119(l) Management of Change
The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process.
In recent years, the number of accidents related to MOC failure is significant and caused by the lacks of MOC management, organisation safety culture, design failure, incompetency, human factor and etc. From the accident statistics published by Chemical Safety and Hazard Investigation Board (CSB-US), European Major Accident Reporting System (EMARS-European), Failure Knowledge Database (FKD-Japan) and Accident Reporting Information Analysis (ARIA-France), MOC contributes significantly to the occurrence of accidents and its percentage contribution to accident rate is not decreasing over the past 20 years.
KTT provides consulting services to help companies improve MOC management process. Our services and e-MOC software enable our clients to manage their MOC more efficiently and effectively.
KTT provides extensive experience consultants to implement post-change review of the client MOCs and regulatory expectations for compliance with the regulations.