Establish that minute-by-minute control must be maintained to achieve acceptable risk levels, and that risk assessments will be made as often as needed while work progresses; this will involve giving instruction on needed action if unanticipat- ed risks of concern are encountered.

8) Identify who wiU accept or decline a change request, including an MOC approval form.

9) Outline a method to determine the actions necessary because of the effect of changes (e.g., providing more employee training; revising stan- dard operating procedures and drawings; updafing emergency plans).

10) Indicate that work wul receive a final review before startup of operations, and idenfify the titles of those who wOl conduct the review.

Responsibility Levels In drafting an MOC system, responsibility lev-

els must be defined and must align with an entity’s orgarüzational stmcture. This is a critical step in developing an MOC system. If even minor pro- cess changes are considered crifical with respect to employee injury and illness potential, possible environmental contaminafion, and product quality and safety, then the levels of responsibility are of- ten many. Some systems used as examples in this article clearly establish responsibility levels, while others do not.

Examples of responsibility levels, as outlined in an organizafion where inherent hazards require close control, are provided as reference points.

•Initiator: The initiator owns the change and is responsible for initiating the change request form. Based on complexities of the changes, these re- sponsibilities may be reassigned at any time. The inifiator fully describes and justifies changes; en- sures that all appropriate departments have as- sessed changes; manages execution of the change request; and ensures that the changes are imple- mented properly.

•Department supervisor: The department su- pervisor assigns qualified personnel to initiate change requests. The change control process is crifi- cal to employee safety, as is avoiding environmental contamination and ensuring product quality. This supervisor ensures that the change request is fea- sible and adequately presented for review.

•Document reviewers: Document reviewers as- sess and approve change request forms. These ac- fivities include reviewing the document for accuracy and adequacy with respect to proposed changes.

•Approvers: Department managers should se- lect preapprovers with expertise related to the na- ture of the proposed change. Based on knowledge and expertise, each reviewer wul evaluate and as- sess the effect of the proposed change on existing processes in his/her area of expertise. Reviewers also must review and approve the change request form and the implementation plan to evaluate the

www.asse.org JULY 2012 ProfessionaiSafety 3 7

change and ensure that the steps for implementa- tion are appropriate. This is the final review before the proposed change is implemented.

•Postimplementation approvers: Department managers should select posfimplementafion approv- ers who should ensure that the change has been ap- propriately implemented as indicated when approval for the requested change was given. This process also ensures that only the changes shown on the change request form have been implemented.

The MOC Process: Activities to Consider An organization’s hazard and risk complexifies

and the desire to establish an adequate yet not complex MOC system shotüd be considered when identifying activities that wül acfivate that system. Activity categories may include the foüowihg:

•Nonroufine and unusual work is to be per- formed.

•Work exposes workers to sources of high energy. •Maintenance operafions for which prejob plan-

ning and safety reviews would be beneficial because of inherent hazards.

•Substanfial equipment replacement work. •Introducfion of new or modified technology, in-

cluding changes to programmable logic controüers. •Modificafions are made in equipment, facüifies

or processes. •New or revised work pracfices or procedures are

infiroduced. •Design specificafions or standards are changed. •Different raw materials wiü be used. •Safety and health devices and equipment wiü be

modified. •The site’s organizafional structure changes sig-

nificantly. •Changes in staffing levels that may affect opera-

fional risks. •Staffing changes require a review of skiü levels. •The site changes how it uses contractors.

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