MOC: Guilty until Proven Innocent (RIK)

MOC has been on of the more confusing and/or challenging elements in the process safety regulations. Why doe MOC seem to be the case? Perhaps because of the connection between poor MOC implementation and several serious PS incidents. Some companies attempt to write an MOC program that will catch every change, which is difficult at best. Where the MOC system has a gatekeeper function, it may appear to work until the gatekeeper changes. To be effective, MOC does require a significant amount of effort, but in a risk-based approach, the effort required should be commensurate with the risk. The conundrum may be that the risk cannot be understood, until some analysis is done and people ado little to no analysis if the change is perceived as Replacement in Kind (RIK).

This paper will discuss some problems with MOC and the key aspects of a successful one. One key is that all changes deserve some review to understand the risk and to verify if it is replacement in kind. Too often, the MOC/RIK screening decision is made to avoid the effort required by MOC. (innocent until proven guilty). A better approach may be to review all changes with the focus being on proving they are MOC until proven as RIK.