NEBSOH are back this month with their expert view on how to make critical modifications to a plant safely.
I am leading a project which involves making critical modifications to our process plant. How can I make sure the changes are managed safely?
Anyone working in high-hazard process industries like the chemical or oil and gas sectors, knows there is always the potential for a major incident. As a result, any proposed changes to plant, no matter how small, need to be managed carefully and with due consideration to the possible implications of those changes.
Effective management of change (or MOC) is therefore a cornerstone of process safety and we can’t emphasise enough how vital it is that before any modifications are carried out, be they temporary or permanent, to software or hardware (and even process personnel), a proportionate and effective MOC process is implemented. Put simply, an MOC process is a formally documented system that identifies the required modifications, supported by relevant documents, approved by all the relevant stakeholders and followed rigorously as the changes are carried out.
It is these three critical factors – hazard evaluation, risk assessment and planning – that should be the focus of your MOC process. By carrying out effective hazard evaluations and risk assessments, you will make sure that the changes won’t introduce uncontrolled and unforeseen new hazards to the process or significantly increase any existing risks. To help achieve this, your MOC process needs to include the following considerations:
- review of the proposed modifications against existing operating parameters and design criteria;
- as well as the installation of any new plant and equipment, evaluation of any planned changes to safety critical devices, replacement of equipment with non-identical alternatives or changes to alarms or other operating parameters;
- changes to key workers or staffing levels needed to implement the changes.
These evaluation considerations will need to be supported by relevant documentation such as design drawings or equipment specifications. The next step is to get authorisation to make the changes.
You will almost certainly need to include the engineering and maintenance managers in the authorisation process but electricians, fitters and other plant workers may also provide important contributions thanks to their working knowledge of the plant. Importantly, you should also get support from a senior manager who can champion it within the organisation. Getting buy-in at a senior level will help position the need for the process within the overall safety culture – it’s important that everyone views the process positively and understands that it is an enabler, not a barrier to getting things done.
The MOC process also has an important role to play in ongoing organisational learning around process safety. By documenting the changes made to process plant or process design, information, knowledge and learning can be retained and applied to any subsequent changes.
The NEBOSH HSE Certificate in Process Safety Management covers the subject of Management of Change in further detail. Launched in partnership with the Health and Safety Executive last year, it provides managers, supervisors and safety professionals with an introduction to risk management as well as an awareness of the hazards and corresponding controls associated with processing activities.