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Management of Change - doe-hdbk-1101-20040095
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Process Safety Management for Highly Hazardous Chemicals - index
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DOE-HDBK-1101-2004
Management of change is addressed under DOE O 5480.19 Chg 2, CONDUCT OF
OPERATIONS REQUIREMENTS, and DOE G 424.1-1, IMPLEMENTATION GUIDE FOR
USE IN ADDRESSING UNREVIEWED SAFETY QUESTION REQUIREMENTS. Programs
that address configuration control also support this element. For new construction, configuration
control is addressed in DOE O 430.1B, REAL PROPERTY ASSET MANAGEMENT.
DOE-STD-1073-2003, Configuration Management, applies to existing facilities. DOE O
420.1A, FACILITY SAFETY, requires that modifications conform to requirements for new
facilities. For years, DOE accident investigation classes have taught the use of a technique called
Change Analysis to identify changes that contribute to accidents. This emphasizes the
importance of a good MOC system in accident prevention, because virtually all accidents
involve some degree of change.
The MOC process should facilitate identification of potential unreviewed safety questions
introduced by process changes. DOE G 424.1-1 describes how such issues should be resolved.
Documentation Requirements
There is no specific documentation requirement for MOC beyond developing a written MOC
procedure and updating the existing process safety information and operating and maintenance
procedures [Q83]. As a practical matter, MOC procedures should include the development of a
request for change form. A sample form is provided in Exhibit 2.10 at the end of this section.
Minimum Implementation Criteria
For a management of change program to be effective, DOE contractor personnel at all levels
must be trained to recognize and understand the ramifications of proposed changes on the safe
operation of a chemical process, including the interdependencies and interrelationships among
facility functions, processes, and activities. For example, a simple change in a valve design may
potentially require changes and modifications to the normal and emergency operating
procedures, maintenance routines, and staff training. Such issues must be resolved before the
change is implemented.
An effective MOC program should contain a means to initiate (request), track, review, and
approve changes. Written MOC procedures must address responsibilities, the basis for a change,
and the impacts of the change, including the following issues.
Assignment of responsibility for requesting changes to existing systems, processes, and
procedures.
Assignment of responsibility for approving changes.
The criteria for approving changes.
Assignment of responsibility for implementing changes.
The basis for the change should be documented on the request for change form, including a
discussion of the technical, safety, and operational needs for the change, and an analysis of the
proposed change, including:
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