This article describes the steps involved in an MOC temporary change and who is responsible for completing each step. A temporary change is designed to only be in place for a predefined amount of time, after which the design is typically reverted to the original. This results in two changes: the temporary change and the change back to the original design.
Note: In this process, the option exists to make a temporary change permanent, if it is determined that the temporary change is more efficient and significantly safer to operate than the original method.
Select each step to read more about it. Select the flowchart image to enlarge it.
Draft (Initiator)
Propose a temporary change and justify the reason for it. Indicate the type, location, and timing for the proposed change, and attach any documentation to support it.
Concept Approval (MOC Coordinator)
All proposed changes go to the MOC Coordinator for concept approval. The Coordinator reviews the change request for completeness and accuracy. The coordinator can approve it and review assigned designers, approvers, implementer, and person responsible for pre-startup review. An expiration date for the change is set.
Options:
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- Send it back to the Initiator for Concept Revision if revisions are necessary before approval.
- Reject the change if needed, where the process ends.
Design Approval (Designers)
After concept approval, the MOC is sent to all selected designers (one by one, in the order designated in the change request) for detailed technical design, which can include editing process equipment and instrumentation diagrams; updating process safety information, risk assessments, and training materials; applying for an operating permit; and developing or updating a risk analysis. Designers can provide comments and request revisions. All related files can be attached or linked to the record.
Depending on the scope and complexity of the change, the MOC may stay in this stage for up to several months. Designers complete their tasks and sign off. When all designers have signed off, the MOC automatically moves to the next stage, Implementation Approval.
Options:
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- Send it back to the Initiator for Concept Revision if revisions are necessary before approval.
- Reject the change if needed, where the process ends.
Implementation Approval (Approvers)
Implementation approvers (area managers, plant managers, EHS managers, etc.) review the change request and supporting documentation, provide comments or requests for revisions, and provide final design approval on a temporary basis. This signals that the physical change can be completed.
Options:
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- Send it back to the Initiator for Concept Revision if revisions are necessary before approval.
- Reject the change if needed, where the process ends.
Pre-Startup Review (responsible party)
At this stage, the change has now been implemented. The MOC Coordinator determined who would complete the pre-startup review during the Concept Approval stage. This individual will
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- complete the pre-startup safety review (PSSR) checklist (built previously) to determine if the change is ready for startup, and
- ensure action items created earlier in process that were required for startup have been addressed.
Option: Create and assign pre-startup action items to address any concerns found. These actions must be completed before the change request can be approved for startup.
Approved for Startup
When all action items that are critical to startup are complete, approval for startup signals that the new or modified process is ready for use.
Temporary Implementation (Implementer)
The temporary process/equipment is activated and the change was successful.
If the change is not complete by the MOC expiration date, request an Extension Approval to ensure that the process is successfully executed.
Note: At this point, if the temporary change is determined to be more efficient and is significantly safer to operate than the original method, it can stay in place:
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- The Implementer submits it to the MOC Coordinator for Permanent Review, rather than reverting to the original state.
- The Coordinator completes the last step in this process to make the change permanent (Design Approval Permanent Workflow).
Post-Startup Review (Implementer)
Complete the post-startup review checklist. If no additional action items are assigned, the record may skip the Pending Action Items stage and move right to Pending Approval to Close.
Pending Approval to Close (MOC Coordinator)
The record is now reviewed to make sure that it is complete. The MOC Coordinator can then close out the MOC.