ࡱ> RQ a\p Anil Gokhale Ba==o68X@"19Arial19Arial19Arial19Arial19Arial19Arial1 9Arial19Arial19Arial1 9Arial"$"#,##0_);\("$"#,##0\)!"$"#,##0_);[Red]\("$"#,##0\)""$"#,##0.00_);\("$"#,##0.00\)'""$"#,##0.00_);[Red]\("$"#,##0.00\)7*2_("$"* #,##0_);_("$"* \(#,##0\);_("$"* "-"_);_(@_).))_(* #,##0_);_(* \(#,##0\);_(* "-"_);_(@_)?,:_("$"* #,##0.00_);_("$"* \(#,##0.00\);_("$"* "-"??_);_(@_)6+1_(* #,##0.00_);_(* \(#,##0.00\);_(* "-"??_);_(@_)                + ) , *  #    H          ! # ( +     `oK Manage Risk!  ;`i c Manage RiskControl Change to Processes"Maintain a Dependable MOC Practice&Assurance of Consistent ImplementationtSubject facilities/activities should establish and implement written procedures to manage changes (except for RIKs).a.No written procedureb.)Simple written procedure for  any changec.Detailed written programd.>Detailed written program with multiple change review protocolssConsider assigning a job function as the  owner of the MOC system to monitor MOC effectiveness on a routine basis. No MOC owner%Part-time MOC owner, local or offsite#Multiple MOC owners across facilitySingle, full-time MOC ownerConsider defining the technical scope of the MOC system so that types of changes to be managed are certain and sources of changes are monitored.Scope not explicitly definedDPlant areas where MOC applies and changes/RIKs are generally defined!Multiple change types are definedFMultiple change types/RIKs are defined with context-sensitive examples,Assurance of Competent Personnel InvolvementdConsider defining the MOC roles and responsibilities of various types of company/facility personnel.,No roles/responsibilities explicitly defined(MOC is made the  responsibility for all <A person is made responsible for all MOCs in each plant areaHAll MOC roles/responsibilities are assigned to job functions/departmentspConsider providing awareness training and refresher training on the MOC system to all employees and contractors.No formal training is provided<MOC practice is broadcast (e.g., email) to everyone one timeEMOC awareness initial training is provided once to affected personnelOMOC awareness initial and refresher training are provided to affected personnelConsider providing detailed training to all affected employees and contractor who are assigned specific roles within the MOC system.+No formal detailed MOC training is provided;MOC detailed training is provided once to key MOC personnelAMOC detailed/refresher training are provided to key MOC personnel-Assurance that MOC Practices Remain EffectiveConsider keeping a running summary log of all MOC reviews, including the items that must be included on an MOC review form to aid in day-to-day management of the MOC process.No log is kept0MOC log is kept in a notebook in each plant area8MOC log is kept electronically in MOC coordinator office[MOC active/inactive log is kept by MOC coordinator and accessible to all affected personneloCompanies/facilities should establish and collect data on MOC performance indicators and efficiency indicators.No data are collected%Basic MOC activity data are collected1MOC performance indicators are collected annuallyAMOC performance and efficiency indicators are collected regularlyNo internal reviews are donenInternal MOC reviews are done, but no  performance information is provided to help reviewers target MOC areasFMOC performance information is provided to internal reviewers annuallygMOC performance and efficiency information is provided to reviewers for regular month/quarterly reviews$Identify Potential Change Situations=Assurance of Adequate Coverage of the Scope of the MOC System{Subject facilities/activities should determine the types of changes to be addressed in the program from an exhaustive list.%No change type categories are defined4Only  hardware and procedure categories are defined%Several change categories are defined4Reasonable complete list of change types are definedaFacilities should document the rationale for not addressing each type of change in their program.No rationale is given3General rationale is understood by MOC  management Rationale is documented @Rationale is documented and accessible to all affected personnel0Assurance that All Sources of Change Are ManagedgFacilities should develop a list of areas, departments, and activities to which the MOC system applies.No list is kept8Plant personnel are told once about applicable MOC areas6Key area personnel are trained on applicable MOC areasBKey MOC personnel are assigned to periodically monitor plant areasFacilities should consider developing a list of personnel, documents, electronic recording systems, etc. to monitor for sources of unrecognized change.5Plant personnel are told once about change types/RIKs7Key area personnel are informed about change types/RIKsEKey MOC personnel are assigned to periodically monitor change sourcesFor each types/categories of changes to be evaluated, subject facilities/activities should develop specific examples of changes and replacements-in-kind for each category to use in employee awareness training in order to minimize the chance that the MOC system is inadvertently bypassed.No examples are developed*A few  generic change types are describedESpecific change types/RIK examples are developed for a few categories|Multiple examples of specific change types/RIK are developed for a all categories; they are updated based on MOC performanceSubject facilities/activities should provide awareness-level and detailed training/refresher training on MOC program to all employees, including contractors.No training provided0Detailed training provided once to key personnel4Awareness initial training provided to all personnelTAwareness and detailed initial and refresher training provided to affected personnelEvaluate Possible Impacts<Assurance of Appropriate Input Information to Manage ChangesFacilities should consider all the types of information necessary to properly evaluate changes within the scope of the MOC system. Facilities should consider developing checklists of appropriate sources of input information for reviewers to use.LNo minimum list of input information for the MOC review process is specifiedhAn informal understanding exists among reviewers about having the necessary information to review an MOC2A checklist of key inputs is provided and enforcedGA checklist of key inputs for each type of change is given and enforced?Assurance of Appropriate Technical Rigor for MOC Review Process&The written MOC procedures should include the use of a MOC review form and should ensure that the following considerations are addressed prior to any change: he technical basis for the proposed change, impact of change on safety and health, authorization requirements for the proposed change.No review form is requiredHA simple review form addressing the three key review issues is specifiedCThe same detailed review form is used for multiple types of changesYA multi-part review form is used to address pre-determined issues for each type of changeCompanies/facilities/activities should use appropriate analytical techniques, including qualitative hazard evaluation methods to review the potential safety and health impacts of a changeBNo hazard evaluation practice exists; reviewers use their judgmentUA generic safety issues/hazard checklist is provided for use in review of all changes0Change-specific hazard review tools are providedKFormal hazard evaluation methods are required under specified circumstances~Provide issues that must be addressed in a review regardless of technique used. Specify quality parameters for review results"No minimum issues list is provided0Each reviewer assembles their own list of issues=A simple, generic list of issues to be considered is providedHChange-type-specific list of issues which must be considered is providedIf temporary changes are allowed, the MOC review procedure should address the allowable time the change can exist and confirmation of the removal or restoration of the change to t< he original condition.No time limit is required=Time limit is specified; no formal follow-up procedure existsGTime limit is specified; the change originator must confirm restoration^Time limit is specified; an independent party must confirm restoration within a specified timeIf emergency changes are allowed, the MOC review procedure should address the definition of emergency change and the process for evaluating the emergency change.INo definition is provided on when an emergency change request can be usedsA vague definition of emergency change is provided and its up to the originator to decide when to use the procedureFSpecific circumstances are given when the emergency change can be usedQSpecific terms are given for use of a specialized emergency change review processAAssurance that MOC Reviewers Have Appropriate Expertise and ToolsMOC reviews should be done by qualified personnel. Facilities should provide the basis for specifying necessary reviewer qualifications.CNo reviewer names or qualifications are specified; anyone can do it,Specific persons are designated as reviewers1Specific job functions are specified as reviewersIReviewer qualifications are specified and designed personnel are approved]Provide description of necessary disciplines needed on an MOC review for each type of change.&No description of disciplines is givenAAn informal practice exists for  senior personnel to be involved;General disciplines are given without regard to change type3Specific disciplines are given for each change type@Each review should include someone qualified in hazard analysis.No requirement existsEReviewers should have some familiarity with hazard evaluation methods(HE training is provided to key personnel5PHA leaders are required for certain types of changesmReviewers should have access to and be trained in the use of company/facility hazard/risk tolerance criteria.No criteria exist%Informal risk guidelines are provided>MOC reviewers are trained on company risk tolerance guidelinesCFormal risk criteria exist and reviewers are trained to follow them!Decide on Whether to Allow Change.Assurance that Changes Are Properly AuthorizedEach MOC should be authorized by a designated approved person. Sometimes the  MOC approver function is satisfied by the MOC reviewers; sometimes the approver is independent of the MOC reviewers.%No independent authorizer is required<The practice requires a senior person to approve all changes5Specific job functions are designated to approve MOCs1Specific personnel are designated to approve MOCsCConsider developing a list of responsibilities for MOC authorizers.9No list exists; authorizers use their judgment/experienceEAn informal understanding exists about the what authorizers are to do/Authorizers are provided general list of dutiesGAuthorizers are provided change-type-specific lists of responsibilitiestMOC procedure should address the issue of providing back-up personnel when designated authorizers are not available.No backup personnel are allowed!No backup personnel are mentioned8General instructions are provided about backup personnel:Specific personnel/job functions are designated as backups;Assurance that Change Authorizers Consider Important Issues`MOC procedure should address the options that reviewers have in making decisions regarding MOCs.(MOC practice does not address this issueHAn informal understanding exists about what options the authorizers have0Authorizers are provided general list of options>Authorizers are provided change-type-specific lists of options_Authorizers should have access appropriate company risk evaluation/tolerance criteria guidance.@MOC authorizers are trained on company risk tolerance guidelinesEFormal risk criteria exist and authorizers are trained to follow them#Follow Through on Results of Change"Assurance that Records Are UpdatedAll process safety information should be updated prior to start-up of the change. If this is not possible, Subject facilities/activities should use  temporary records (e.g., red-lined P&IDs, procedures) and then track incomplete items regularly until they are brought up to date, reviewed, and approved. Subject facilities/activities should consider specifying a maximum length of time that should not be exceeded without information being updated (e.g., 90 days) after implementation of the proposed change.No emphasis on updating PSKD3Red-lined PSKD is kept until the next normal update$Personnel monitor the update of PKSD1All PSKD must be updated before change is started=Assurance that Changes Are Properly Communicated to PersonneltCompanies/facilities/activities should communicate changes to potentially affected personnel, including contractors. Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, or trained in, the change prior to start-up of the process or affected part of the process.+No reliable communication on changes occursCInformal communication/training on changes occur for some personnelXFormal system exists for informing/training personnel on changes for operating personnelgFormal system exists for informing/training personnel on changes for all potentially affected personneltCompanies/facilities should document that the training was completed and that the employees understood the training.)No reliable training documentation occursLInformal logs are kept of people to whom change information was communicatedXFormal system exists for documenting which personnel were informed of/trained on changessFormal system exists for documenting the communication/training on all changes was understood by affected personnel0Assurance that Risk Control Measures Are EnactedCompanies/facilities should create a system to address MOC review action items and to document their completion. The facility should address which should be completed before the change is implemented and which can be completed following the change.No action item follow-up occurs1Informal measures for action item follow-up exist;Formal system exists for action item tracking to completionbFormal system exists for action item tracking to completion before and after change implementationQMeasures to restore conditions of expiring temporary changes should be confirmed.BNo measures for confirming temporary MOC restoration are specified@Informal measures for confirming temporary MOC restoration exist>Formal measures for confirming temporary MOC restoration existNPersonnel are designated to confirm restoration of temporary change conditionsIf emergency changes are allowed and the MOC procedure allows authorization of changes without the immediate updating of records, measures should be established to ensure that the MOC procedures are completed as defined for emergency MOC situations within a designated time.,No emergency MOC follow-through is specified8Emergency MOC review risk control measures are specifiedhEmergency MOC reviews are followed by completing the normal MOC procedure within a specified time periodEmergency MOC reviews are accompanied by temporary risk control measures until completion of the normal MOC procedure within a specified time period)Assurance that MO<C Records Are MaintainedMOC review packages should be prepared, containing materials and information used by reviewers and authorizers to perform the review. Review packages should be retained for a specified period (e.g., 1 to 5 years) to support other RBPS work activities.No MOC records are kept/Minimal MOC records are kept for a brief periodKExtensive MOC records are kept until next hard/risk assessment revalidationMExtensive MOC records are archived electronically for the life of the process=Management of Change Pre-startup Safety ReviewCompanies/facilities should provide input to internal audits of MOC practices based upon learnings from the MOC performance indicators.p ] 6 |.  gY"%I(|+-5}/s2 4 q6<>qA,DGccv a ,CLSo[c}lta|  dMbP?_*+M%"??U} I} I} } ltht--,+*)('&%$#"!            ~ ?              ~ @                ~ @             ~ @            ~ @            !~ @  " Dl&&&&&&&&&&&&&&&&&&&&&&&&& !"#$%&'()*+,-./0123456789:;<=>?   # !! ! 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