June 26, 2020
As stated in a previous post, Management of Change (MOC) is a core foundational element for managing operational risk well. In fact, MOC touches nearly every business process in a manufacturing facility. Taking that logic a step further, we can see that MOC is implicitly tied to the dynamic nature of risk. Therefore, the supporting engineering information for MOC needs to be updated as things change – or as the relationships among processes are impacted due to a change.
Let’s talk about change at a closer level. Whenever there is a shift handover, there are points of concern caused by “change.” Something as subtle as an alarm that is shelved or a safety instrumented system that is bypassed represents a change. What if someone calls in sick or takes a personal day off… doesn’t that represent a change? Right after a turnaround, the risk profile of equipment has often changed or effectively been reset.
In another common scenario, what happens if the work that was planned for a shift isn’t completed? Again, that represents a change and that change, with its impacts, needs to be communicated to the oncoming shift. As plants go from sold out to cost containment mode, they will likely undergo operational changes. Should we change our spares holding strategy when changing between these two operating modes? Does capital expenditure matter more when we are in cost containment mode? Does reliability matter as much in that operating mode?
Change is a constant force that challenges us to adapt and to understand the impacts being imparted. In fact, MOC is the interface point or juncture box of process interoperability. Without an effective MOC culture that recognizes “change” and its impacts as more than a change to physical equipment or process parameters, we could be acting on information that isn’t current – leading to additional risk. So, if how people consistently do things is governed by Conduct of Operations (CoO), then shouldn’t MOC and CoO work together? When they do… we tend to execute more consistently. As procedures and equipment are changed, we still need to achieve operational discipline. In fact, companies need to double down and ensure they have a sound foundation for Conduct of Operations to enable their workforce to take action based upon the right information at the right time.
Cutting capital expenditures doesn’t mean we don’t have to worry about compliance… that isn’t going to change. We might want to move to do risk-based inspection instead of time-based inspection in tougher times to reduce inspection intervals where that applies, but if the change we needed to effect in good times never quite got prioritized to implement, we might not be able to.
Some MOCs are required for safety and compliance. Others are based on potential efficiency gains. In tough times (i.e. at a lower cracking spread in a refinery) we may shelve a change until it becomes economically feasible. And that is a change to the change. Shelving a change is easy, but is it done out of hand or is there an associated risk assessment for deferring safety and environmental driven changes that is a consequence of changing the change?
Envision an operating environment where the procedure to perform a task (i.e., start up a piece of equipment, change a valve, perform routine maintenance) is connected to that task and that job role and work assignment. That would mean, for instance, that if shift handover indicates that on this shift the maintenance technician needs to perform a valve change as part of a Connected Workforce informed by MOC and CoO, would know from their device:
And, all of that info would already be on their device as they headed on shift, because of their assigned job role and known work assignments. In this scenario, if the change we mentioned earlier, of someone calling in sick, does happen… the assignment and all attendant information can be reassigned to another qualified person on the incoming shift. The change in personnel is effectively and proactively managed because the MOC and CoO functions are both present in this Connected Workforce environment.