ࡱ> 76 a\p Anil Gokhale Ba==z:!8X@"1Arial1Arial1Arial1Arial1. Times New Roman1.Times New Roman1.Times New Roman1. Times New Roman1 Arial1.Times New Roman"$"#,##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_);_(* \(#,##0.00\);_(* "-"??_);_(@_)"Yes";"Yes";"No""True";"True";"False""On";"On";"Off"                + ) , *                `+Sheet1HSheet2ISheet3 OLE_LINK1:`i 3MOC IMPLEMENTATION PATHOLOGIES/PROPOSED CORRECTIONS.Develop written procedures for managing change'Written procedure has not been prepared Not perceived as needed/intended0Intended, perhaps in progress, but not completedExpedite completionCInvolve representatives of affected groups in procedure developmentWWritten procedure defines physical and/or analytical scope of application in LTA mannerScope not clearly defined]Consider regulatory and corporate requirements in defining both physical and analytical scopegConsider including  non-traditional issues such as management of change of organization with the scopeiTo the degree feasible, document what is outside the scope of coverage, as well as what is with the scope@Scope not large enough to encompass all safety-significant areas9Ensure that all regulatory/corporate requirements are metInclude service and support systems that could have an impact of the operation or integrity of the systems that are directly related to safety performance\Consult process hazard analyses, and other hazard/risk studies for input when defining scope=Scope too large, unwieldy, unworkable for available resourceseConsider efficiency enhancements that can be obtained by trimming to a more  safety-essential scope.& then provide resources & AWritten procedure defines implementation activities in LTA mannerActivities not clearly defined6Defined activities do not address all MOC requirements\Defined activities significantly exceed MOC requirements, unworkable for available resourcesImplement MOC procedureGMOC system newly instituted, insufficient opportunity to build momentumJWholesale disregard for MOC system; effectively, system is not implementedCLack of management endorsement/imperative for system implementation9Willful avoidance of MOC controls on a case-by-case basis'Lack of awareness of value/need for MOC6Resistance to change and structure associated with MOCQPerceived insufficiency of resources provides disincentive for MOC implementationFPerceived time constraints provide disincentive for MOC implementation+Unintentional failure to apply MOC controls!Lack of awareness of requirements*Insufficient understanding of requirements#Confusion over scope of application)Failure to recognize a change as a change;System too large or complex and implementation bogging down+Address the technical basis for each changeTechnical basis not addressedNot addressed in procedureProcedure requirements unclearIntentionally omitted&Insufficient detail in technical basis#Complexity of change underestimated6Inadequate consideration/development of change concept;Expertise of MOC originator/developer insufficient for task"Too much detail in technical basisExtraneous detail includedErrors in technical basis3Inadequate technical/peer review of technical basis.Nature/scope of change not properly understood<Evaluate potential safety and health impacts for each changeEvaluation not conductedPEvaluation tool not appropriate to the nature of the change  insufficient rigor%Significance of change underestimated2Simpler tool chosen to expedite evaluation process-Staff lacks expertise to use appropriate tool4Tool selection constrained by overly rigid procedureKEvaluation tool not appropriate to the nature of the change  to much rigor$Significance of change overestimated)Desire to be conservative in the analysis+Proper tool selected, but not used properly5Facilitator insufficiently experienced in use of tool>Inadequate information available upon which to base evaluationETeam make-up does not provide proper mix of expertise and perspective2Insufficient time or attention devoted to analysis;Recommendations not formulated to properly address concerns@Analytical errors by evaluation team, fails to identify concernsCRecommendation formulated is not appropriate to address the concern/Recommendation intentionally omitted/suppressed.Recommendations not resolved on a timely basisALack of management reinforcement/imperative for timely resolution$Appropriate schedule not established6Responsibilities/accountabilities not clearly assigned/Insufficient resources available for resolution,Insufficient resources devoted to resolution1Control the duration of the change (if temporary)8Procedure does not adequately address duration of changeNot addressed at allRequirements unclear$Appropriate duration not establishedLFailure to recognize that change should be implemented as a temporary change^Failure to recognize that change would be more appropriately implemented as a permanent changeEInsufficient/incorrect analysis establishes excessively long duration/Excessively long duration established by intent<Duration of temporary changes established but not controlled Wholesale disregard for controls9Inadvertent failure to restore system to normal conditionHNo system for extending durations of temporary changes for valid reasons=Failure to successfully return system to normal, upon attempt/Insufficient documentation of what  normal was;Failure to properly, or completely, restore prior condition(Address the need for  emergency changes7Procedure does not adequately address emergency changes/Failure to adhere to emergency change procedure@Define/implement requirements for authorizing changes to be made@Procedure does not adequately address authorization requirementsONo protocol provided for identifying who should review and approve MOC requestsProtocol provided, but it does not adequately address the range of technical expertise potentially appropriate/required for the gamut of change categoriesKApproval requirements intentionally streamlined, to an inappropriate degree2Authorization requirements not properly identified9Nature or significance of change not properly appreciated[Necessary/appropriate approvals omitted from requirements to expedite authorization process.Required/specified authorizations not obtained)Individual not available to authorize MOC@Provide system for designating alternate MOC reviewers/approversHReinforce that MOC may not be implemented without all required approvals$Individual declines to authorize MOC/Authorization obtained after MOC is implemented8Insufficient collaboration among MOC reviewers/approversVAppropriately inform and train affected employees and contractors before changes occurBProcedure does not adequately address the need to inform and trainDInsufficiently addresses scope with respect to who should be trainedWInsufficiently addresses scope with respect to what sort of training should be providedProvisions not made for follow-up training to address shift schedules, absences, etc., to ensure all required personnel are informed/trained!Willful avoidance of requirements:Lack of awareness of value/need for informing and trainingIPerceived insufficiency of resources provides disincentive for compliance>Perceived time constraints provide disincentive for complianceUnintentional failure to complyTInformation/training provided not adequate for the nature/significance of the changeHAppropriate documentation of informing/training performed not maintained<Update any process safety information affected by the changeSProcedure does not adequately address the need to update process safety informationnInsufficiently addresses scope with respect to the types of information that should be considered for updatingkInsufficient guidance for identifying those changes which warrant updating a particular type of informationGLack of awareness of val<0ue/need for updating process safety informationNResources not sufficient to ensure timely update of process safety informationLUpdate any procedures (including safe work practices) affected by the changeCProcedure does not adequately address the need to update proceduresmInsufficiently addresses scope with respect to the types of procedures that should be considered for updating7Lack of awareness of value/need for updating procedures>Resources not sufficient to ensure timely update of proceduresWBlue text indicates the key activities required to successfully implement an MOC systemQPurple text indicates a primary problem encountered in achieving the key activity7Green text indicates an underying cause for the problemDBlack text indicates a potential solution for addressing the problem W  8Q \  b P8D!#n%(4*cc a (15h:>xCHH  dMbP?_*+A%MXerox WorkCentre Pro C3545 (Kno$C odXXLetterDINU"49XRX10XX$(xlew@fghijopqrdzZ|}00"dXX??U} Column AX  ; ; ; ; ; ; ; ; ; ; ; ; ; ;;;;;;;;;;;;;;;;;                              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