Management of Change reviewers

Perform process hazards analysis Perform management of change review... 

Equipment inspec- Reevaluate and possibly reset inspection intervals tion may provide a when equipment is used for handling different poor prediction of chemistry equipment safety, Perform management of change review due to change of material handled or change in process chemistry over the life of equipment. ... 

Not in-kind Ensure that the replacement satisfies the require-replacements (e.g., ments of duty gaskets, rupture, Implement management of change review disks, packing, mechanical seals) resulting in failure. Possibility of hazardous release. CCPS G-22 CCPS G-27 CCPS Y-28 OSHA 1910.119... 

Conduct thorough evaluation of process modification using management of change review procedure... 

Perform process hazard analyses Perform Management of Change review... 

Engineering design and risk reviews (such as process hazard analyses or management of change reviews)... 

For new processes, the modification has been subjected to management of change review and all recommendations have been resolved or implemented before start-up... 

NEVER make temporary unauthorized repairs on equipment in hazardous material service without a management of change review by qualified personnel. 

The second case considered by the standard is where the SIS is not fault tolerant and is providing protection in a demand mode. Continued operation within the MTTR is taken into account in the calculation of the probability of random hardware failure. However, in this case, there is no protection until the faulted device is repaired and returned to service. Therefore, when continuing operation with a disabled SIF, compensating measures should be identified that provide risk reduction equivalent to that provided by the SIF in the absence of the fault. These compensating measures should be documented in the operation and maintenance procedures so that personnel are trained on their appropriate use. To continue operation beyond the MTTR, a management of change review should be conducted to ensure that the compensating measures identified are sufficient for extended operation and that priority has been placed on the repair. 

It is incumbent upon the toller to develop and follow internal management systems as appropriate to support business needs, production needs, process safety, environmental responsibility, and worker health. The selection process should have considered whether or not satisfactory systems are in place. Nevertheless, the contract or auxiliary documents may be the vehicle used to help ensure that the system reviewed is the system actually used for completing the toll in question. Within the process safety management system, the management of change and training elements are essential subsystems. 

The review and approval process for procedures for the toll needs to be clearly understood between the toller and their client. This can be addressed in the management of change system. A preliminary process or batch procedure may be written or proposed as part of the toller selection process or may be included in the initial... 

An overall review of the management of change documentation package should be performed to ensure documentation update items (including material safety data sheets) are addressed and that PHA action items are complete. This can be done by one person but is often best achieved by a PSSR Team. The process needs to account for ... 

If a product has not been tolled for an extended period (some companies use six months), it is essential to check the management of change documentation packages for all of the equipment involved. This review should focus on ensuring changes made between the new request to toll and the last time the product was tolled do not... 

Changes made to modify the process/facility have been reviewed and authorized by the ABC Co. Management of Change program. ... 

If properly established, the management of change mutual-review agreement and designated points of contact should preclude most... 

The effort and time that is required for a process hazard analysis for these examples should not be an issue. A thorough management of change system will call for the change coordinator to make a decision as to what type of review is appropriate for the change. 

Management of change A system to identify, review and approve all modifications to equipment, procedures, raw materials and processing conditions, other than replacement in kind, prior to implementation. 

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

Maintenance (Mechanical Integrity) —Pre-Startup Review —Management of Change —Safety Audits — Accident Investigation... 

Pre-Startup Safety Review Mechanical Integrity Hot Work Permit Management of Change Incident Investigation Emergency Planning and Response Compliance Audits Trade Secrets... 

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