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- Prepared By
Kashyap Patel
Presentation Overview
What is Management of Change? Why do We Need MOC?
What is Change?
Change vs. Replacement Types of Changes Permanent vs. Temporary Change MOC Program Training Information Management System
Auditing
Success of MOC Case Study of Sector 5 Flash Fire Incident
Prior to implementing changes, there shall be a system to ensure that prospective changes such as design, operation & maintenance etc. are evaluated for their potential risk impacts to pipeline integrity along with impact on the environment
MOC program is used to ensure all changes to a process are properly reviewed and any hazards introduced by the change are identified, analyzed, and controlled before resuming operation
Example: Upgrading of SR from B-50 to B-200 due to frequent UPSO due to increase in downstream consumption Change in PRS skid because of change in pressure values of GSPL at CGS terminal
hydrocarbons began to flow from the formation into the well and resulted into massive blowout.
What is Change?
Change is an alteration or adjustment to any component, variable or property within an existing system (except those within clearly defined boundaries or responsibilities). The most difficult part of management of change is recognizing that a change is taking place. It is essential that employees can distinguish between when the MOC procedure is required and when it is not. (For example, the replacement of a valve with an identical valve would not require approval through the MOC system, while the addition of Globe valve in place of ball valve would.) It is also important to be able to recognize the difference between safety critical and non-safety critical changes
They are equipment and procedural alterations that vary from the documented design specifications.
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Types of Changes
1. Change of Process Technology: When facility was initially design, safeguards were built in to keep the process from exceeding safe operating limits. If the parts of the process are changed then a review should be conducted to ensure that it does not compromises process safety 2. Change of Facility: The introduction of new equipment could also introduce hazard or increase risk 3. Organizational Change: Occur through transfer of employee to new assignments or through reduction/increasing the staff. It is very important that this to be recognized as change and the employee gets safety related knowledge required to carry out the new responsibility 4. Variance Procedure: Occurs when operation supervisor/engineer/manager wishes to deviate from the standard procedures. A review of the procedure should be conducted and appropriate approval received before the variance took place
Examples of Temporary Changes: 1. Temporary not providing the UPS system at CNG station due to repairing/maintenance work 2. Temporary running transformer without vacuum circuit breaker unit 3. Temporary disconnecting second stream of PRS system due to maintenance 4. Replacement workers
MOC Program
I. Proposal
1. Identification Identification of the changes required is the most difficult part & thus extremely important part of MOC system Systemic approach for identification can be used. The employee can use the list as a check-list to determine if the modification falls under any of the categories. Developing a clear, written, definitions of a system boundaries and what constitutes change for effectively identifying change requirement
Example: Suppose a downstream network of 3000 SCMH DRS has been expanded over a period of time and more & more commercial & domestic customers are connected through this DRS. Now daily monitoring, recording and analyzing the pressure values of upstream and downstream of DRS at peak flow condition can be helpful for identifying whether change or modification or replacement of DRS with higher capacity is required or not.
I. Proposal
2. Plan for situation Step by step plan preparation of executing a change Steps to be taken to control the change, MOC guide for employee Defining time limit for executing permanent or temporary change Define technical or non technically staff involved in the process. Helps in assigning responsibilities during MOC
3. Control Mechanism
4. Time Limit
5. Staff involved:
Define whether change is technically benefited or commercial benefited or whether change is necessary for continuing the operation
Develop a form or template for recording the reason of change
Example: To determine the causes of not up grading the installed DRS or evaluate installation of new DRS based on cost incurred and revenue generation
Risk ranking based on hazard level & potential severity associated with change. Yes/No questionnaires type format can be developed and based on score, risk matrix to be developed to determine over all risk level
III. Approval
1. Permission & Communication:
Whether 5 approval signatures and a thorough hazard analysis or 1 approval signature and no formal risk assessment required? Risk ranking system to determine authorization level
IV. Execution
1. Work Permits: Obtaining work permit as per work permit matrix before executing job
2. Monitoring:
Monitoring the parameters of system like pressure, temp. etc for a specified time to determine functionality of changes applied
3. Implications: Study the outcomes as per checklist or a form of expected changes in system in order to determine success level of MOC plan
V. Documentation
Documentation of entire MOC plan in a uniform format Completion Report
Training
Training is important achieve the success of a MOC program as it will only function on the level that employees are trained to properly use it. Process safety could be put at risk during a MOC execution by the unintentional actions of one untrained individual. Employees must possess the proper respect for management of change and they can only acquire this through training. Anyone who could affect a change must be aware of and conform to the policies and procedures of change control. It is equally important for both management and regular staff to receive program awareness training as they all play an active role in the MOC process.
Auditing
Audits are used to ensure that the MOC system is working as effectively as possible. No matter how good a system is, there is always room for improvement, and audits are a way of continuously improving the MOC program. The audits determine whether all changes are assessed for their impact on safety and whether the documentation of the change is accurate and complete. If a MOC system is new then more frequent audits should be performed during the initial stages to ensure all the bugs are found.
Success of MOC
Management Support Implementation more than documentation Understanding & utilizing developed procedures Training & Awareness
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3. The air gas mixture in the filter of the skid rushed due to depressurization in the downstream of the system and the impurities in the filter ignited the mixture. (most possible cause for ignition)
Role of MOC
Sr.
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Steps
Identification
Descriptions
As it was clear instruction from GSPL, we had a proper reason to identify changes required in the system in order make our system compatible with the pressure of transmission line This part could have clearly evaluated that what is to be done in order to incorporate the changes. Like was it really necessary to check the system? which process to be adopted?, Could there have been any other better method than functional test?
Evaluation
Step wise planning have been made to carry out functional test of all facilities which are going to be affected due to increase in pressure in GSPL line
Role of MOC
Sr.
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Steps
Control Mechanism
Descriptions
Work flow procedure plan could have been prepared based on policy and procedures of company to carry out functional test like deciding venting points, purging point, use of regulators etc in order to control the process Determining the time limit for completing entire job at all three location. As per permit taken for the job we can see that all three locations functional test were planned in a single day. Thus this could have serve as a checkpoint whether the time limit planned is sufficient or it requires more time
Time Limit
Role of MOC
Sr.
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Steps
Staff Involved
Descriptions
This could have help in deciding the staff involved in procedure such that other operations could not have affected. Clearly defines the roles and responsibilities of each person involved in the operation Based on the potential severity and hazard associated with the hazard associated with the functional test & N2 purging ,risk ranking could have been done to determine overall risk level. This could have been check point for determining percentage of N2 present in the cylinder and risk associated with filter cartridge Based on risk rating it could have been determined the level authorization required to execute the change. Like whether GA head approval or GM-T approval or AGM HSE approval were required before executing the job
Risk Ranking
Approving Authority
Role of MOC
Sr.
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Steps
Work Permit
Descriptions
Based on authority level of approval, this have helped in taking signatures of all approving authority so that they can be awaked about the operation is under progress. This can have serve as a checkpoint of all compliance and procedures
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Permission or Communication
It might have helped in deciding whether third party information or communication was required or not like communication to CNG vehicle customers as a safety precautions before job execution
Role of MOC
Sr.
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Steps
Monitoring
Descriptions
Functional test gone unsuccessful at Vijay Petroleum. Thus continuous monitoring was necessary of the system and its parameters in order to eliminate any malfunction that could have resulted because of the test Based on expected results, yes no type checklist might have been prepared to analyze the success of MOC Documentation of entire MOC plan and procedure. This must have included step wise approved procedures to be executed, signed & approved P&ID diagram defining venting & purging point during test, tool box talk, risk rating, hazard identification & steps taken to mitigate hazards associated with test, list of staff involved with clear roles and responsibility etc documents
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