(176b) Implementing an Effective Management of Change (MOC) System for E&p Business and Non- PSM Facilities

The upstream oil and gas industry involves processing high volume of live data during different operations (such as drilling, production, well servicing etc.) and thereby generating high volume of process or procedure changes. It is very important to manage these changes as based on the past incidents in the industry it can be noted that accidents often occurs after changes. Any change that has safety implications should be carefully evaluated, including performing a hazard analysis, before it is allowed. One of the practicable approach in managing these changes is by implementing a Management of Change (MOC) system.
 
Most companies have policies for management of change, but the implementation and enforcement of these policies can vary greatly. An effective MOC work process includes a review and authorization process for evaluating proposed adjustments to facility design, operations, organization or activities prior to implementation to make certain that no unforeseen new hazards are introduced and that the risk of the existing hazards to employee, the public, or the environment is not unknowingly increased. It also includes steps to help ensure that potentially affected personnel are notified of the change and that pertinent document, such as procedures, process safety knowledge, and so forth, are kept up-to-date.
 
The main aim of this paper is to address the three basic questions (what? why? and how?) in implementing an effective MOC system. There are more robust MOC program available for the facilities covered under OSHA Process Safety Management program. However the management of change (MOC) work process mentioned in this paper is fit for purpose for upstream oil and gas operation. This paper discusses challenges in implementing MOC system for facilities not covered under OSHA Process Safety Management program and addresses common misconceptions of Management of Change system.
 

A well-designed MOC process is an essential loss prevention tool for any business. It is not just for certain hazardous industries. The process applies to any company that wishes to avoid future losses resulting from today’s changes. MOC does not have to be overwhelming or so difficult to use that it inhibits change. It cannot effortlessly compensate for past omissions, only reduce your future risk. So the time to start developing and implementing an effective MOC process is today.