Management of Change: Temporary Changes
We continue our discussion to do with Management of Change (MOC). Previous posts in this series are:
Types of Change
If change is to be managed properly, it is necessary to understand the types of change that are typically made on a facility — each will require its own response. Changes can be categorized as follows:
Initiated change;
Non-initiated change;
Temporary change;
Emergency change; and
Administrative and organizational change.
In this post we look at Temporary Change.
Temporary Change
Temporary changes have a built-in termination date or time. Changes of this type are often implemented to keep the operation running while a piece of equipment is repaired or replaced.
From a safety and operational point of view, whether a change is permanent or temporary is merely a semantic matter — the system itself does not know or care that a change is intended to be temporary. Therefore, the fact that a proposed change is defined as being temporary does not mean that it can be handled less rigorously than a permanent change. Yet, because of the short duration of many temporary changes, the personnel implementing them may be tempted to take short cuts, particularly if going through the MOC process takes longer than actually making the change itself. There is a temptation to take an attitude of, ‘Let’s just get on with it — why bother spending hours writing and reviewing an operation that will only take a few minutes to carry out? We don’t have time for all this bureaucracy.’
Although it is easy to reproach someone who takes this point of view, it has to be recognized that temporary changes often need to be implemented quickly in order to avoid more serious problems from developing. Indeed, many temporary changes are also emergency changes.
An example of a situation that can tempt personnel to take an unacceptable short cut is shown in the sketch. A hazardous chemical is leaking to the atmosphere through a control valve’s packing. Operations management decides to run a hose bypass around the valve, and to control the flow in the line using a manual valve. The leaking control valve can then be blocked in and repaired.
This repair activity may take no more than 30 minutes. Yet it is a new operation, so the system has changed, even though these activities could take hours, far longer than the change itself. The following are part of the management of this temporary change.
Conduct a safety analysis ― probably using some type of What-If method. The analysis should focus on the feasibility of controlling the flow of chemical using a manually-operated block valve.
Write a temporary operating procedure.
Train the operators in the new procedure.
Prepare an emergency response plan in case the modification does not work properly.
Make sure that the temporary hose is removed once the repair work is complete, that all valves are returned to their normal position, and that blinds are installed on the bypass block valves.
It is important to distinguish between true Temporary Changes and those changes that have occurred at least once before and that are repeated at infrequent intervals. Such changes are ‘Infrequent Repeat Changes’. If the change has been carried out before, and if it was properly managed, then, strictly speaking, it does not need to be put through the Management of Change system when it is carried out a second time.
This approach to the management of infrequent repeat change is only valid, however, if the change, when it was previously made, was properly controlled and documented. If the records are inadequate or incomplete then the Management of Change process will have to be implemented a second time. People may have memories as to what was done, but this is not sufficient; the information must be written down. Moreover, if the change has not been implemented for some time, there is a good chance that not all of the current personnel will have been trained to operate the facility in the new mode. Hence, in this situation, it is best to treat the change as if it is entirely new, and to train people again.
