(159a) Auditing MOC: A Target-Rich Environment

This presentation provides an opportunity to look back over several years of audit results and highlight specific challenges to properly evaluate and mitigate the risk of several proposed changes.

As with any process or procedure, MOC procedures cannot be sufficiently detailed to cover every imaginable change situation. While most MOC processes have a quality review component, they often only verify that certain boxes are checked at the appropriate time within the workflow. Depending on the technical safety competencies of the individuals executing the MOC and/or performing the quality reviews, an organization may not identify opportunities to improve the effectiveness of the program.

Auditing MOC provides an opportunity to identify and address those challenging areas leading to poor execution. A thorough audit should uncover more than issues with the procedure and the workflow. To provide assurance of an effective MOC program, audits must ensure that process hazards are properly identified and addressed. Using an auditor with a strong background in Technical Safety will lend credibility to the audit process, and provide constructive feedback to improve performance in MOC execution.

Based on audits across a range of operations, MOC quality issues have been observed in the following areas, which will be discussed in this presentation:

• Transitioning from a temporary change to a permanent installation: What someone might approve for a short duration is not necessarily what might be appropriate indefinitely.
• Late project field changes: What happens in the MOC process when specifically engineered kit is brought to a turnaround jobsite and does not fit?
• Functional Reviews:
  • Identification of appropriate reviews, and appropriate reviewers. (Acoustic Induced Vibration??? What’s that??)
  • SME commentary does not automatically create a trackable action item.
  • Conducting reviews in silos, the unintended consequence of removing human interaction when pushing the process with electronic workflow.
• Process Hazards Analysis vs Risk Assessment: Is it a HAZOP-or-nothing proposition, or are there alternative methods for understanding hazards and risk impact?
• Emergency MOC: Resisting the urge. Does an Emergency MOC become an emergency for the organization?

During the discussion of each case study, the presenter will provide ideas suggesting how the proposed change may have been managed more effectively.