Questions - hdbk11010097

DOE-HDBK-1101-96

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.

Questions

83.

What documentation is needed to demonstrate compliance with MOC requirements?

Other than having a written MOC procedure, no specific documentation is required for MOC

beyond updating existing PSI and operating and maintenance procedures. However, many

process safety experts agree that having a request for change form is necessary to document

changes. These forms should contain enough information to ascertain that all considerations

required under the PSM Rule for each change have been resolved.