(55bb) Best Practice in MOC and Pssr Automation for Opex

Management of Change (MOC) and Pre Start-up Safety Review (PSSR) are still the most challenging elements of OSHA’s Process Safety Management (PSM) standard and the EPA’s Risk Management Program (RMP) rule. Now MOC and PSSR are requirements of the US Department of Interior’s Bureau of Safety and Environmental Enforcement’s Safety and Environmental Management Systems (SEMS). Even though the PSM standard has been around since 1992 and the industry has been managing change for several decades, we still can get it wrong, sometimes with disastrous results. The mindful or diligent efforts of many working in concert are necessary to ensure that change is identified, analyzed and executed in a quality way. But just when we get the process on paper and get the workforce up-to-speed, we have employee turnover, complacency sets in and sometimes there is regulatory change.

Many high-profile companies have addressed this challenge by creating and automating standard processes across their manufacturing or production facilities. MOC and PSSR are two of these major processes that have been successfully automated or digitized. Technology has been used to automate each step of the MOC workflow, enabling the collection of change ideas, formalizing the analysis of the ideas, and documenting the approval and execution of the change. Reports and dashboards can provide visibility of the health or current state of your MOC and PSSR processes. The use of software can enable the standardization of best practices.

On a well-meaning quest to standardize on a MOC/PSSR software solution and process, many companies are stifling creativity and innovation. Operational Excellence cannot be achieved in such ways. This paper discusses how the chemical process industry has defined the MOC and PSSR best management practices and how they should be automated for operational excellence.