Management of Change: Other Process Safety Elements
Defining Change
We continue our discussion to do with the challenge of defining ‘change’ in the context of Management of Change (MOC). Previous posts in this series are:
We have seen that MOC suffers from a dilemma that is endemic to other process safety elements: circular logic. In the context of MOC this dilemma expresses itself in the following conundrum.
We use Management of Change (MOC) to evaluate critical changes.
How do we know if a change is critical?
We conduct an MOC to find out.
Rather than struggling with attempts to define the word ‘change’, another way of understanding MOC is to see if the proposed change affects any of the other elements of process safety. If it does, then the proposed ‘change’ is a ‘Change’. Examples are:
A P&ID has to be updated;
An operating procedure has to be modified; and
The emergency response plan has to be restructured.
It would be great if there was a generally accepted list of change categories, hopefully no more than 10 say, which would cover equipment, process materials, key documentation, critical procedures, safety critical elements (as defined in the UK), key competence requirements and ??? I would also include organisational changes relating to process safety management