(57cc) Where Does Management of Change (MOC) Begin?

Management of Change is often affiliated with an operating facility. However, several projects have the common challenge of being developed within the constraints of an aggressive schedule, considering the time from project kick-off until unit start-up. In order to comply with the deadlines, early releases of engineering design documentation become subject to changes. During project development, these changes may come as scope changes, supplier updates, etc. that may affect more than one engineering discipline and any on-going construction/assembly activities. Another change source may be non-conformances identified during the construction/assembly phase. In this case, considering project milestones and costs, an option taken into account is to leave the system or portion the way it is instead of re-working to match the original design. For all of the given cases, a robust Engineering Management of Change (EMOC) process must be in place throughout the project life cycle to guarantee modifications are properly identified, communicated, and evaluated by technical experts for possible effects on process and design safety prior to implementation, or at a minimum, prior to startup of the system/subsystem. In addition, an EMOC process gives the opportunity to analyze the reasons for the modifications in order to avoid increased costs and design errors on future projects, leading to improved quality control. This paper presents some previous accidents related to management of changes, and addresses EMOC implementation, work process and elements of a successful EMOC program.