Why MOC is part of the core fabric for Intelligent Operations
September 20, 2019
By David Drerup
One of the core framework components of Intelligent Operations is Management of Change (MOC). MOC is rather like a skeletal system as is exists to reduce the likelihood of incidents, but more holistically, it deals with sustainability of supporting business processes as changes occur. While MOC is largely driven by regulatory compliance needs in the EH&S world, in the workforce aspects, MOC is important because changes affect organizational ability to execute core business functions on a daily basis. The EH&S part of MOC that is captured in formal management systems is generally well understood in the process industries. On the other hand, the informal work practices that are affected by MOC often get overlooked. The result of missed changes are typically increased economic and safety risk.
Companies constantly deal with MOC by creating procedures around it, but the complexity of equipment and technology change alone is often daunting for organizations to execute on a daily basis. Developing a culture that willingly initiates all required MOCs is critical, but this is just the beginning. While the right person in the MOC Coordinator role may make the right decisions based on their education and experience, what happens when the hazard assessment methodology is a choice such that one facility requires a HAZOP and another facility with the same change does not? Organizational MOC that supports sustainable business processes and reduces both economic and safety risk should be designed such that it drives everyone through the same requirements based on the potential risk of the change.
The interoperability of key safety aspects such as MOC, Corrective and Preventative Action (CAPA), Incident Management and Process Hazard Analysis (PHA) afforded by Intelligent Operations is important as it automatically routes information and ensures key processes and knowledge is protected and distributed. For instance, an Intelligent Operations approach means that when we evaluate a change, we ask if the change is a Replacement In-Kind or Not-In-Kind, and the connected systems can then create the necessary bridges to the right work process… regardless of the operator or facilitator’s individual experience or knowledge. In fact, CAPA is a supporting process that needs to be included for non-MOC action items to avoid items falling through the cracks. Adherence to organizational standards is no longer beholden to the discretion of one human making a decision at some point along the pathway.
A core premise of Intelligent Operations assumes that MOC is woven into the core fabric. As such, MOC should be incorporated into the management systems, policies and procedures to ensure that change – no matter the type – is recognized as an integral part of all supporting business processes.
Some examples of change that is compartmentalized at a departmental level but need to be managed holistically include:
- Inspection – Adding a chemical injection point, exceeding an Integrity Operating Window (IOW) limit
- Operations – Changing staffing levels on a shift, changing an alarm setpoint, bypassing a Safety Instrumented System (SIS)
- Supply Chain – Changing suppliers, modifying spares holding levels
- Production – Enhancing plant capacity, changing the plant alignment
- EH&S/Process Safety – Modifying a procedure, adding a new piece of equipment
- Engineering – Re-engineering a pump, adding additional independent protective layers due to an equipment criticality change
One of the blinds spots of traditional MOC is that different departments own portions of the entire MOC pie. For example, Automation and Process Safety may both deal with alarm setpoint changes, while Maintenance and Process Safety interact with SIS (i.e. proof testing and calibration, vs changes). All the stakeholders must be involved with relevant changes. If Automation has their own MOC process how can we assure that all the potential impacts of the change are being analyzed? Intelligent Operations, with its core of holistic MOC across the organizations many departments and processes, solves this challenge.
The historical consequences from industry learnings of misapplied or overlooked changes are numerous and can be costly. For example, poor MOC as it pertains to alarm setpoint changes can cost $100,000 – $150,000 to address in a unit in a chemical processing facility leading to an alarm rationalization initiative. The inadvertent ordering of spare parts based on lack of understanding of what constitutes a change leads to ordering the wrong equipment for the required application leading to tying up capability along with potential for tax consequences for carrying inventory too long. The bottom line is poor MOC costs money, not to mention the associated safety risks…
What does the maturity roadmap look like by phase?
So how does Intelligent Operations change this?
A simple pump change is a great illustration of the interoperable nature of change in a practical sense. If an MOC is initiated on a pump, the supporting functions must all work together to accomplish the change:
- Engineering (to determine the design and update the drawings)
- Maintenance (to address work management and work permitting)
- Quality assurance (to ensure the pump is properly aligned)
- Supply chain (for ordering of a new pump)
- Operations (to update the procedure)
In Intelligent Operations, these departments can function seamlessly to enable a more efficient work process in the right order. If the proposed change is for a pump that will require additional maintenance procedures and training, shouldn’t that be known up front? The change may still go forward but there are countless cases where familiar equipment could have been used and a “new and better” design had been used in the past and failed in the application. Intelligent Operations also delivers a continuous improvement outcome by helping organizations learn from patterns by analyzing data across the fleet to identify anomalies that were hard to detect at a localized level. Without this sort of core capability, organizations are prone to repeat MOCs without learning and driving out inherent engineering defects.
What is the efficiency worth? For every 100 MOCs enacted in a refinery/petrochemical processing facility, the cost savings for efficient execution of change is between $90,000 – $135,000 USD per year.
- Assumes simple MOCs @15 hours and complex MOCs @50 hours
- Efficiency gain of 40-60% over paper-based MOC
MOC is primarily seen as a regulatory compliance function to address EH&S and process safety risks. To make it more effective as a vital organizational development and operational tool, it is part of the core fabric driving Intelligent Operations. While much of MOC is informally being done in companies today, it makes addressing change extremely human intensive. Once companies re-architect MOC, they can use it to drive supporting processes and reduce the effort to govern their organization.
We will discuss additional core framework principles to Intelligent Operations in coming articles including Enterprise Loss Prevention, and Engineering Information.