(44j) Is Your MOC Process Doing All That It Should Be?

OSHA 1910.119 Process Safety Management of Highly Hazardous Chemicals was the driver for refining and chemical industry to implement Management of Change (MOC) programs some 20+ years ago. However, companies have now recognized the benefits of implementing and maintaining an effective MOC program beyond regulatory compliance.  Effective MOC programs enhance a company’s ability to respond to changing “market” or processing needs with up to date process safety information.  Management of Change has even been incorporated into staffing levels and personnel expertise by some Companies.

Management of Change programs typically focus on changes that are “not in kind” changes.  Significant effort is placed on proper evaluation of these changes and the potential impacts on the operation.  This presentation emphasizes both the typical and non-typical areas of MOC that have been found to be overlooked.  MOC programs rigorously evaluate the potential to introduce new hazards of the process such as fire, explosion, toxicity, and environmental impacts.  Is that far enough to ensure that you are meeting all of your performance needs? 

Focus on environmental impacts such as water contamination, air pollutants, and hazardous waste generation may not be going far enough.  Gradual increases in highly hazardous material inventories may cross the lines of “threshold quantities” and introduce new OSHA or EPA requirements.  Does your MOC program look at this potential?  In addition, management of “in kind” changes may also not be keeping pace with the changes required by the EPA Leak Detection and Repair (LDAR) requirements or the Benzene Waste Operations NESHAP (BWON) requirements.  These requirements as applied to MOC are further explained in this presentation.  Several “gaps” in MOC programs will also be examined and suggestions for improvements provided.