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By Sam McNair, P.E., CMRP, Life Cycle Engineering
Have you ever had one of those nights? The only spare parts in stock don’t fit because that little “midnight upgrade” you did last year failed to provide for new spares. Maybe your line has been down for hours as your electrician tries to troubleshoot using a hopelessly out-of-date drawing. Or did you suffer a near miss because of that uncapped line that was added as an undocumented afterthought and not included in the isolation plan? Have your operators ever damaged a new piece of equipment that they were not trained on? Have you ever had one of those great workarounds that was “just the answer” in the heat of the night, just to fall flat and create more problems than it solved? And I’m sure every one of you knows of some location that has suffered a terrible accident because of an unauthorized substitution or “minor” change. If any of these have been true for you, you need to learn about what effective management of change is and how it can protect your people, your plant and your bottom line.
Although implementation details vary widely, truly effective management of change (MOC) programs start from the same foundation and contain the same basic elements, either singly or in combination. The following 11 steps give you the basic functional guidelines.
What am I really planning to do here? Quite often where no effective MOC process exists, requests for a change are rather vague: “run a temporary line from here to there,” accompanied by some hand waving. It happens all too often. How big should the pipe be? What pipe material spec? What size and expected flow? Exactly where should it terminate? How about valves? You need simple sketches, red-lined drawings, marked-up procedures or whatever is necessary to convey the nature and extent of the change to a knowledgeable and competent third party. Be clear, be concise, but be complete. If you can’t communicate clearly what it is that you wish to do, how can a team evaluate it properly and how can you ensure that what you intend to do will in fact be implemented properly? At this point in the process the change must be defined well enough that you can make a good decision in subsequent steps.
“If you don’t have a proxy system for approvals in place, by all means develop one.”
The most important step in an established MOC process is asking the simple question: Should I be doing this at all? What concrete business objectives am I satisfying by this change? Is there truly a compelling business case, or is this simply a matter of convenience or expediency? If there’s not a clear reward that can be stated in terms of accepted business goals, why are you using the resources and why are you taking the risk? Just how big are the risks? Again, being clear and concise are the keys. “Increasing temperature by 2° C will increase yield by 0.07% and result in 27,000 lb per year of increased throughput at a variable margin of $0.20/lb resulting in $5,400/year gross revenue. This change in control strategy will decrease nuisance trips by four per year, reducing overtime by 400 hours, valued at $20,000 per year.” These fit both criteria quite well.
No change is entirely risk-free, so get over it. And quite often the person proposing the change is the last person to be wholly objective in evaluating risk. Even if one person is wholly objective, that person rarely is all-knowing. The evaluation of risk requires the MOC team approach. Use as a minimum the “three-person rule” for assessing the risk of a proposed change. The criteria for selecting someone to be part of the team are simple.