Temporary Management of Change: A Problem or a Necessary Part of Managing Process Safety

Temporary Management of Change (MoC) projects seem to be the boogeyman of Process Safety Management (PSM). These temporary changes are frequently needed, but feared by operating company management, compliance groups, and lawyers. Some concerns regarding temporary MoCs are valid while other concerns may be based on false assumptions or incorrect interpretations of regulation. Most alarming, many of the concerns regarding temporary MoCs may lead to worse practices and the potential to introduce more risk into the business. This paper explores the reasons for this aversion to temporary MoCs and proposes a paradigm shift. Instead of considering permanence as the norm, consider that everything is actually temporary. The key is designing, operating, and maintaining for the appropriate window of time. The change will only be approved if the risk falls within accepted company protocol for the required duration of the change. The author will define five categories of temporary MoCs for the purpose of clarifying that one-size-fits-all duration limits and protocols are not appropriate. The author will address three myths regarding practices for managing temporary MoCs that may lead to unintended negative consequences. And finally, the author will propose preferred practices that avoid these unintended outcomes leading to more efficient work processes and safer operations. The need for temporary MoCs and the risks of mismanagement of those temporary MoCs must be well understood by both regulatory agencies and operating companies. Policies and procedures must drive practices that assure safe operation for any time horizon given real world impacts and constraints.