operational risk management

History Defines Needs & Difficulties of Application At least 25 years ago, the chemical and process

industries recognized the importance of having an MOC process in place as an element within an op- erational risk management system. That awareness developed because of several major incidents that occurred when changes were taking place.

In 1989, Center for Chemical Process Safety (CCPS) issued Guidelines for Technical Manage- ment of Process Safety which included an MOC element. In 1993, Chemical Manufacturers Asso- ciation published A Manager’s Guide to Implement- ing and Improving Management of Change Systems.

In 2008, CCPS issued Guidelines for Management of Change for Process Safety, which extends the pre- vious publications. From the preface:

The concept and need to properly manage • change are not new; many companies have implemented management of change (MOC) systems. Yet incidents and near misses at- tributable to inadequate MOC systems, or to subtle, previously unrecognized sources of change (e.g., organizational changes), con- tinue to occur.

To improve the performance of MOC sys- tems throughout industry, managers need advice on how to better institutionalize MOC systems within their companies and facilities and to adapt such systems to managing non- traditional sources of change, (p. xüi)

Note that incidents and near misses (near hits) attiributable to inadequate MOC systems continue to occur. Also, organizational changes are being recognized as a previously unrecognized source from which MOC difficulties could arise. As noted by CCPS (2008), “Management of change is one of the most important elements of a process safety management system” (p. 1).

MOC Requirements in Standards & Guidelines Several standards and guidelines require or sug-

gest that an MOC process be instituted, including:

•ANSI/AIHA ZlO-2005, American National Standard for Occupational Health and Safety Man- agement Systems, which requires that an MOC process be implemented (Secfion 5.1.2).

•BS OHSAS 18001:2007, Occupational Health and Safety Management Systems Requirements, which states, “For the management of change, the organization shall identify the OH&S hazards, and OIÍ&S risks . . . prior to the introduction of such changes” (Section 4.3.1).

•OSHA comments on change analysis in its Safety and Health Management System eTool: Worksite Analysis.

Anytime something new is brought into the workplace, be it a piece of equipment, differ- ent materials, a new process or an entirely new building, new hazards may uninten- tionally be introduced. Any worksite change- should be analyzed thoroughly beforehand because this analysis helps head off prob- lems before they develop.

Provisions that require MOC systems may have different names. For example. Section 7.3.7 of ANSI/ASQ Q9001-2000, Quality Management Systems: Requirements, is titled “Control of design and development changes.” It states:

Design and development changes shall be identified and records maintained. The changes shall be reviewed, verified and vali- dated, as appropriate, and approved before implementation. The review of design and development changes shall include evalua- fion of the effect of the changes on constituent parts and product already delivered. Records of the results of the review of changes and any necessary actions shall be maintained.

The MOC Process As with all management systems, an adminis-

trative procedure must be written to communicate what the MOC system encompasses and how it should operate. The system should be designed to be compatible with the organizafion’s and indus- try’s inherent risks; management systems in place; organizational structure; dominant culture; and ex- pected workforce participafion.

Although brevity is the goal, several subjects should be considered for inclusion in an MOC pro- cedure:

1) Define the need for and the purpose of an MOC system.

2) Establish accountability levels. 3) Specify criteria that will trigger formal change

requests. 4) Specify how personnel will submit change re-

quests and what form will be used. 5) Outline criteria for request reviews, as well as

responsibilities for those reviews. 6) Indicate that the MOC system encompasses:

•risks to those performing the work and other affected employees;

•possible property damage and business in- terruption;

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