Are Management of Change Systems Like Snowflakes

You could very easily conclude that nowadays, several years after the OSHA Process Safety Management standard, most companies have similar MOC systems. That is just not true. Most MOC systems are different at each corporation, and somewhat different at each location. Most MOC systems are like snowflakes, most are significantly different in details than the MOC system at the organization down the road. 

To illustrate the point, at a three-hour meeting at McNeese State University s OSHA Support Group in Lake Charles, four major nationally recognized chemical plants and refineries described the details of their MOC systems in November 1997. The four companies described major system differences and about five more attending companies provided information regarding their approaches. There were distinct differences in the review and authorization process philosophy. 

Each chemical plant and refinery must adopt or develop a procedure tailored to fit the specific hazards, the available technical resources, the culture of the organization, and any required governmental regulations. It must be practical and workable without undue delays. Keep in mind that a modest MOC system that is regularly used and works is much better than an elaborate, sophisticated system with an impeccable paper trail that is occasionally winked at, bypassed, or sometimes totally ignored. 

Essential elements of an effective management of change policy would include a program in which all employees  

A hasty modification can result in an accident, as discussed in Chapter 6. To address the problems of one-minute modifications, chemical plant management must persistently encourage employee awareness and train their employees about the potential dangers that can be created by the quick, inexpensive substitutions. It is essential that well-maintained engineering and equipment specifications are readily available. Changes which might include improper substitutes (such as incompatible materials of construction) or improper procedures should be reviewed by a third party. However, this is sometimes easier said than done in the sometimes hectic p e of maintaining maintenance and production schedules. 

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