Management-of-change procedures

Use chemical interaction matrices to identify potential incompatibilities between combinations of materials (not just binary reactions) and interactions with cleaning solvents, heat transfer fluids and other utilities, equipment lubricants, scrubbing media, materials of construction, etc. Implement management of change procedures for changes in design, operation, equipment and chemistry. 

Review design and construction changes for safety (follow Management of Change procedures). 

A clearance sheet tracks the changes through the management of change procedures. A typical change form may include the description and purpose of the change, the technical basis for... 

Training for all plant personnel on the new Management of Change procedure was completed and the procedure became mandatory. 

The Woodlawn Plant has completed installation of its Management of Change procedure, and the Kingston Plant is continuing to implement process hazard assessment. The assignment of a new plant manager to the Winston Plant has delayed their installation efforts by one month. 

Pre-start-up Safety Review (PSSR) approval of the SIS establishes the point where the SIS design and construction is considered complete. All documentation should be formally updated to as-built status, incorporating any modifications made since the last formal drawing or document revision. Once the PSSR has approved the SIS for process unit start-up, formal management of change procedures should be followed to address proposed modification to the SIS or its associated documentation. Any deviation from the approved design basis should be reviewed and approved by appropriate parties prior to change implementation. 

Controls and sign-offs in the work order system that ensure Management of Change procedures are followed. 

This may require alterations to the Management of Change procedure to improve its effectiveness for identifying and examining changes that effect fire protection. Possible procedure alterations may include addition of the following ... 

Specific questions relating to fire prevention and protection and emergency response added to the Management of Change procedure s process for review of potential hazards. 

Management-of-change procedures that require proper review of all changes to the design or operation of a plant ... 

Therefore, if a leak-detection system has been installed to warn of releases of toxic or flammable materials from a plant, the implementation of a process safety management system should include the detection system as part of the process (CCPS 1989 CCPS 1988). In this manner the leak-detection system will be subject to the facility s management-of-change procedures, and changes to the leak-detection system, will be carefully evaluated before being implemented. 

In specific extraordinary situations it may be necessary to temporarily increase the setpoint or bypass or deactivate some type of instrumentation or other equipment safeguard. However, this should only be done in an established manner, according to appropriate Management of Change procedures with proper approval. Furthermore, any special defeat to a safeguard should be properly signaled for the operators and documented in a special way. Operators and supervisors must regularly review that out-of-compliance log or alarm point summary so that the defeated system can be properly restored at the earliest possible time. 

It is crucial that companies refrain from making their management of change procedures so restrictive or so bureaucratic that motivated individuals try to circumvent the procedures. Mandatory requirements for a list of multiple autographs is not necessarily (by itself) helpful. Excessively complicated paperwork schemes and procedures that are perceived as ritualistic delay tactics must be avoided. Engineers, by training, have the ability to create... 

Table 11-2 Key Steps in an Effective Management of Change Procedure...

Requirements may be identified that will need to be addressed before the Management of Change procedure is complete. The second-level supervisor or department head is responsible to assure that suspended items within the PSSR are completed. Suspended items could include updating master drawings with the hand-corrected as built mark-ups, completing the documentation to set up proof tests or vessel inspections or other important items that should not necessarily delay a startup. 

The material in this long chapter may not cover the needs of every chemical plant and every petro-chemical plant, but the ten or fifteen Management of Change procedures developed by major corporations and reviewed by me did not seem to exactly fit the needs or culture of my own organization. Trevor Kletz has said many times that improper plant modifications have been a major cause of chemical plant accidents. I have been working in a process safety function for three decades and my experiences have been similar. It just seems appropriate to repeat the first three paragraphs of the second section of this chapter, as a fitting close. 

Note 1 Refer to Management of Change procedures, level of safety review determined by magnitude of change to process (Ref. Section 6.3). 

Since a multitude of different changes may occur at a facility, the company s Management of Change procedures should define the type of process hazard analysis required by the change and these requirements are beyond the scope of this guideline. 

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