The following lessons have been learned in industry when setting up MOC programs:
- Don’t focus solely on equipment modifications – other changes are equally relevant to MOC procedures (eg. changes in operating procedures, staffing levels, and maintenance procedures).
- Don’t have unnecessarily tight equipment specifications – will cause MOC to be used much more often then would have been necessarily had more thought gone into the original operating procedures and mechanical specifications. eg. using only catalog replacements instead of having functional descriptions of spare parts.
- Applies to all process units, not just those containing flammable or toxic substances – when dealing with hazardous materials, MOC should apply to indirect systems (eg. utility boilers)
- Make sure there is easy access to documentation – the correct information must be available to the team conducting the safety review.
- Save all records – both approved and disapproved – some facilities saved only approved records. If the same change was requested again at a later date the initial safety review and reasons for disapproval are not available. Also disapproved records are useful during audits.
- Make sure EVERYONE is aware of MOC program – improper program awareness training will lead to incidents.
- MOC must address both types of risk – its important that the risk assessment looks at both types of associated risk. There’s short term risks which arise while the change is taking place. There’s also long-term risks which can arise after the change has been implemented.