Questions - doe-hdbk-1101-20040097

DOE-HDBK-1101-2004

acceptable safety/risk assessment methods and approaches;

impact on potential for release;

format and content of the analysis.

Impacts of the proposed change include:

procedures, functions, processes, and activities, such as maintenance and operation

additional training needs

additional resource requirements.

The level of review should be commensurate with the potential risk associated with the change

[Q84]. A MOC program for contractors with simple chemical processes may consist of

appropriate review of a change request form. For more complex processes, it may be necessary

to modify the work order/work request system and the process required for approval of capital

projects.

Change includes both capital changes and daily changes associated with maintenance and

operations. Daily changes are more subtle and therefore more likely to be overlooked. Examples

include substitution of parts that may affect a process or deviations from operating or

maintenance procedures. Replacement-in-kind changes must be defined based on process safety

issues in a facility. An overly restrictive definition may be excessively burdensome and costly

[Q85].

An effective MOC program should also include an assessment procedure to determine the

importance of the change to process safety and a procedure to manage each proposed change.

This procedure should enable management to:

determine the level and effort required for review and implementation of a change;

update PSI and PrHAs and address any resulting recommendations;

modify operating procedures;

inform affected employees and subcontractors;

retrain affected employees;

update emergency plans;

develop a schedule [Q86] and a list of required authorizations;

update pre-startup procedural changes;

modify pre-startup inspection and testing procedures; and

verify mechanical and system integrity prior to startup.

The MOC tracking and approval system may be integrated into existing systems. Because

change of even an inexpensive component may result in a catastrophic release, changes covered

in the MOC tracking system must be based on risk rather than cost. Finally, an effective MOC

program should include a method to audit the MOC program to ensure it is working.

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