MANAGEMENT OF CHANGE AND COMPLIANCE
A company wanted to modify a chemical process at one
of its older facilities to make it more productive and competitive with
newer technology currently used in the industry. Project planning and
obtaining budget approvals was assigned to the production department.
Subsequently, all the necessary construction contracts were issued, new
equipment purchased, and scheduling finalized. Work began on a weekend
in mid-January and was halted that Monday. Why?
Upon arrival at the facility on Monday morning, the EHS manager saw the
work in progress and was surprised to see the installation of new
equipment. The production department had never submitted the project
plan to EHS for review. The Production Manager explained that the work
was only a modification to the current process and he did not realize
that the work may be subject to any regulatory requirements. The EHS
Manager had no choice but to request that further work be suspended
until a complete and thorough review of procedural and equipment changes
was completed. Upon review of the plan the EHS Manager found that the
process modification resulted in the following:
• Increase in process throughput
• Increase in air emissions
• Increase in pollutant loading to the facility’s waste water treatment
system
In addition, the modified process would also require retraining of the
current operators prior to start-up. Unfortunately, several of the above
items required the facility to obtain appropriate environmental permits
prior to initiation of the project. The work was suspended at
considerable inconvenience, potential economic loss, and additional
Agency scrutiny.
The company did not have a written “management of change (MOC)” program
which would have provided the necessary management procedures and
sign-offs required when procedural or equipment changes are
contemplated. An effective MOC program prevents events such as the above
from occurring. Although, the illustration above describes an
environmental permitting situation, most MOC events are not as obvious.
They comprise more routine activities that may impact the health and
safety of employees including such “minor issues” as personnel changes
in key positions and changing the set points of safety equipment (i.e.,
pressure relief valves).
The objective of a Management of Change (MOC) program is to ensure all
process changes are properly identified, analyzed and controlled prior
to starting or resuming operation. Note that an MOC program is
specifically required under the OSHA Process Safety Management (PSM)
standard 29 CFR 1910.119 (l)(1) and the EPA Chemical Accident Prevention
Provisions (also known as RMP) under 40 CFR 68.75. However, every
company, whether required by the regulations or not, would greatly
benefit by establishing a written program for managing operational
changes. A properly written and managed MOC program prevents accidents
and reduces liability.
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