Documentation Requirements

DOE-HDBK-1101-96

is addressed in DOE O 430.1, LIFE CYCLE ASSET MANAGEMENT. DOE-STD-1073-93, Guide

for Operational Configuration Management Program, applies to existing facilities. DOE O 420.1,

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 DOE O 424.1 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 isssues.

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:

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