Change Approvals, Documentation, and Auditing

A responsive modification review and approval system with competent reviewers can gain acceptance quickly. If a modification approval system is unnecessarily cumbersome, there can be tension between the sponsor and the reviewer or there can be attempts to circumvent any proposal. 

We all must realize that a modification control system, especially for the many little but vital changes, must not be so formal that an answer cannot be expected in a reasonably short time. A multiple-layer system must be in place to deal with the entire range of proposals from the very simple change to the very complex. 

Common sense and the OSHA Chemical Process Safety Management Law requires an audit of compliance to the Management of Change. Periodic review and documentation of a site s activities in managing aspects of personnel and process safety is often a part of an organization s culture. A good audit can measure the actual versus intended effectiveness of various programs. 

Each organization must devise its own way to conduct an audit. Other readers may wish to consider details of Audits and Corrective Actions or Chapter 13 of Plant Guidelines for Technical Management of Chemical Process Safety [4], which covers broad topics such as Scope, Staffing, Frequency, Reports, and Internal and External Auditors. It is not the intent of this book to cover that aspect of auditing. 

Some Generic Management of Change Audit Questions 

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