MOC Request Form An MOC request form is needed, and its content
should align with an organization’s structure and in-place management systems (e.g., capital request procedures, work orders, purchasing procedures). Creating a digital form aüows flexibility for descrip- five data and comments. The form should include:
•name of person initiafing the request; •date of request; •department or section or area; •equipment, facüity or processes affected; •brief descripfion of proposed change and what
wiü be accomplished; •potenfial performance and SH&E consider-
ations; •titles and names of personnel who wül review
the change; •effect on standard operating procedures, main-
tenance, training and simüar functions; •space for reviewers to document special condi-
tions or requirements; •approvals and authorizations; •routing indicators or provisions for copies to be
sent to personnel responsible for training and up- dating operafing procedures, drawings and similar documents.
Sample change request forms can be found in some of the 10 examples posted in PS Extra (www .asse.org/psextra).
Implementing the MOC Process Senior management and safety professionals
rnust appreciate the magnitude of the task of ini- tiating and implementing an MOC system, and should expect push-back. Common obstacles in- clude egos, territorial prerogafives, the current power structure and normal resistance to change; remember, those affected may have had little expe- rience with the administrative systems being pro- posed. Although MOC systems have been required in the chemical industries for many years, the liter- ature reports that their applicafion has experienced difficulties. According to CCPS (2008):
Even though the concept and benefits of managing change are not new, the matu- rafion of MOC programs within industries has been slow, and many companies sfiü struggle with implemenfing effective MOC systems. This is partly due to the significant levels of resources and management com- mitment that are required to implement and improve such systems. MOC may represent the biggest challenge to culture change that a company faces, (p. 10)
Developing an effective MOC system may require evolufion in a compan/s culture; it also demands significant commitment from Une management, departmental support or- ganizations, and employees, (p. 11)
Management commitment, evidenced by pro- viding adequate resources and the leadership re- quired to achieve the necessary culture change, must be emphasized. Stated or written manage- ment commitment that is not followed by provid- ing the necessary resources is not management commitment. Because of extensive procedural re- visions necessary when initiating an MOC system, culture change methods should be applied. Sub- jects to consider when implementing the system include the foüowing:
•Management commitment and leadership must be obtained and demonstrated. That means pro- viding personal direcfion and involvement in ini- tiating procedures; providing adequate resources; and making appropriate decisions with respect to safety when disagreement arises about the change review process.
•Keep procedures as simple as practicable. An applied, less-complicated system achieves better results than an unused complex system.
•Obtain widespread acceptance and commit- ment. Inform all affected employees before inifiat- ing the MOC system, solicit their input, and respect their perspectives and concerns.
•Recognize the need for and provide necessary training.
3 8 ProfessionalSafety JULY 2012 www.asse.org
•Field-test a system before implementing it. De- bugging will produce long-term returns.
•After refining the system through a field test, select a job or an activity that would benefit—both productivity/efficiency and safety—from an MOC system, and emphasize those benefits to buud fa- vorable interest. Tesfing the system in a select ac- tivity demonstrates its value, makes it credible and creates demand for additional applicafions.
•Monitor system progress and performance via periodic audits, and informally ask employees for their perspectives.
Managing Organizational Change In some examples posted, procedures require
those involved to assess the significance of organi- zafional changes. These provisions exist because or- ganizational and personnel changes can negafively affect an operational risk management system.
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