(54b) But We're Only... (Do we really need to do an MOC?)

In many organizations, the formal Management of Change process is frequently considered burdensome by personnel trying to implement changes to a process. It can add cost to a project. It can force conversations and involvement with other departments. It can prevent workarounds designed to keep a process running. It almost always slows down the process. Because of this, process engineers, project engineers, operators, maintenance personnel, and sometimes management look for ways to bypass the formal system in favor of a simplified review. One of the most frequent questions I have been asked as a Process Safety Manager is, “Do we have to do an MOC for this?” This was usually followed by a very cursory description of the change to be made and a comment such as:

“We’re only (or just)…”, followed by an attempt to minimize the scope of the change

“We’re actually making things safer.”

“We’re actually improving the process.”

Over time, I started to answer this question with a quotation from the movie, I, Robot. “You must ask the right question?”

I would then explain that the right question is not, “Do we need to do an MOC?”. The right question is, “What is the appropriate way to manage this change?” All changes need to be managed. Some changes are managed by following procedures and using specified materials. Where this is not the case, the formal Management of Change process is in place to ensure that the change is not going to result in unintended negative consequences.

The purpose of this talk is to give some examples of changes that were not properly managed because they were small or because the people making the change believed they were making things better or safer. The results of these changes will be discussed, some of which are catastrophic. Some of these examples come from the energy and chemical industries, but others come from totally unrelated industries such as farming and ski tourism. In all cases, they point out that improperly managed changes can result in negative consequences.

It is expected that the audience will take away the following from this presentation:

A renewed appreciation for the importance of managing all, even small, changes;

Some examples to use for explaining this importance to personnel in their facilities; and

A better understanding of the difference between “doing an MOC” and managing a change.

As an added benefit, I found that some people would rather do the MOC than listen to me explain why they might need to.