This article describes the steps involved in an MOC permanent change and who is responsible for completing each step. A permanent change stays in place for the life span of the affected process or procedure.
Select each step to read more about it. Select the flowchart image to enlarge it.
Draft (Initiator)
Propose a permanent change and justify the reason for it. Indicate the type, location, and timing for the proposed change, and attach any documentation to support it.
You might discuss all proposed changes in a meeting where you "pre-approve" them before entering them into the system, but you can use the Draft stage as a way of communicating proposed changes.
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.
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 change request 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 change request may stay in this stage for up to several months. Designers complete their tasks and sign off. When all designers have signed off, the change request 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. This signals that the actual 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
- 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 (Implementer)
When all actions are complete, approval for startup signals that the new or modified process is ready for use. The Implementer
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- reviews information submitted,
- provides approval to start up at the site based on the site schedule, and
- alerts parties to start related training and communication.
Post-Startup Review (Implementer)
The Implementer completes the post-startup safety review checklist to ensure that everything was implemented correctly and safely.
Option: If there are any Pending Action Items that need to be completed, the Implementer assigns them now.
Pending Approval to Close (MOC Coordinator)
The MOC Coordinator will review the record, including action items, to confirm that everything is in order. If there are any outstanding issues, they can be corrected now, before closing. When the record is complete, the Coordinator can close it.