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Process safety series · Part 3 of 3

Management of Change for Small Plants

Contents
  1. What counts as a change
  2. Worked example 1: a faster addition
  3. Worked example 2: a cheaper solvent
  4. The MOC procedure
  5. A one-page MOC form
  6. Five ways MOC fails in practice

Most process incidents do not start with a bad design. They start with a good design that was changed. A faster addition to gain capacity, a cheaper solvent, a temporary pipe to keep running during a repair: each looks small, and each can remove a safeguard that someone added for a reason.

Management of change, or MOC, is the procedure that catches this. Before a change is made, someone who understands the design checks what it affects. MOC is an element of process safety management standards, including CSA Z767 in Canada and the OSHA process safety management rule in the United States.

Post 1 and Post 2 built up the safeguards on one reactor and its feed heater. This post shows how quickly a change could undo them, and how a small plant can run MOC without a large safety department.

What counts as a change

The key test is whether the replacement is in kind: identical to what it replaces, or a different item that meets the same specification. A replacement in kind needs no MOC. Everything else does.

Table 1. Change or replacement in kind?

SituationNeeds MOC?Why
Gasket replaced with the same specificationNoReplacement in kind
Pump replaced with the same modelNoReplacement in kind
Pump replaced with a larger modelYesHigher flow can exceed what the reactor can cool
Addition time shortenedYesChanges the heat release rate and the accumulation
Solvent from a new supplier, same specificationUsually noCheck the specification covers the properties that matter
Different solventYesChanges the boiling point, MTT in Post 1
Alarm or trip set point changedYesThe safeguard no longer acts where the HAZOP assumed
Trip bypassed to keep runningYesRemoves a safeguard, even if only for a shift
Temporary hose or pipeYesTemporary changes need the same review, plus an end date

Worked example 1: a faster addition

The plant from the scale-up series runs 1,000 batches a year on an eight-hour cycle that includes a three-hour addition. Sales want more product. Cutting the addition to two hours shortens the cycle to 7 hours and gives about 1,143 batches a year, 14% more output without new equipment.

The MOC review starts from the design numbers. The reaction releases 1.5 GJ per batch. Spread over the addition time, that gives the average heat the jacket must remove.

0 kW50 kW100 kW150 kW200 kW250 kW2 h additionProposed208 kW2.5 h addition167 kW3 h additionCurrent design139 kWJacket can remove 154 kW
Figure 1. Average heat release during the addition against the jacket capacity of 154 kW. The two-hour addition exceeds it.

Table 2. What the review finds for a two-hour addition

CheckThree hours (current)Two hours (proposed)Source
Average heat release139 kW208 kW1.5 GJ over the addition time
Jacket capacity154 kW154 kWScale-up Part 1
Temperature controlHolds 60 °CBatch temperature risesHeat release above capacity
Accumulation20%Higher; needs new calorimetryFaster feed, same reaction rate
High flow trip (HAZOP action 7)Set for three hoursWould have to be raisedRemoves a safeguard

The change is not safe as proposed. The review does not have to end with a refusal, though. It can point to options that are: a larger cooling capacity, a lower coolant temperature, or a second reactor. Each of those is a change with its own MOC.

Worked example 2: a cheaper solvent

Purchasing finds a solvent that does the same job at a lower price, but it boils at 95 °C instead of 110 °C. The process chemistry is unchanged.

In Post 1, the boiling point is MTT. At normal accumulation the MTSR is 75 °C, still below 95 °C. But the margin to boiling falls from 35 K to 20 K, and the accumulation at which a cooling failure would reach boiling drops from 67% to 47%. A cold-feed event, the case found in Post 2, now reaches boiling sooner. The condenser, the vent and the solvent recovery design all assumed the old boiling point.

Nothing in this change looks like engineering, which is why it is easy to miss. That is the case for routing purchasing changes to raw materials through the MOC screen.

The MOC procedure

Every change goes through the screen. Only changes that are not like for like go on to the review.ChangerequestedReplacementin kind?YesNormal work orderNoHazard reviewscaled to riskApproveImplementUpdate drawings,procedures, trainingPre-start-upcheck, then close
Figure 2. A management of change procedure. The screen sends like-for-like work straight to maintenance, and the review is scaled to the risk of the change.

A small plant does not need a HAZOP for every change. Scale the review to the risk.

Table 3. Review level by type of change

Type of changeExampleReview
Low riskA new instrument of a different make with the same range and functionChecklist, signed by the process engineer
Medium riskNew alarm set point, different raw material supplier"What if" review with an engineer and an operator
High riskFaster addition, new solvent, bypass of a tripHAZOP of the affected nodes, approved by the plant manager

A one-page MOC form

Table 4. Fields on a one-page MOC form

FieldWhat to record
DescriptionWhat will change, where, and why
Permanent or temporaryFor a temporary change, the date it must be removed
Screen resultReplacement in kind, or the risk level for review
Effects checkedProcess conditions, safeguards, relief, materials, operating procedures, environment
Review and findingsWho reviewed it, the method used and the actions
ApprovalName, role and date
Documents to updateP&IDs, procedures, alarm and trip lists, training records
Pre-start-up checkInstalled as approved, people trained, documents updated
ClosedName and date

Five ways MOC fails in practice

  • Temporary becomes permanent. A temporary change has no end date, so it is never reviewed again.
  • Small changes add up. Each change passes on its own, and together they remove the margin. Review the history of the unit, not only the latest request.
  • Drawings fall behind. The plant no longer matches the P&ID, and the next HAZOP studies a plant that does not exist.
  • Purchasing and staffing changes skip the screen. A new supplier or a reduced crew can change the hazard as much as new pipework.
  • The operators are not told. A change is only complete when the people running the plant know what is different.

Takeaway. Screen every change, and scale the review to the risk. In the example, a two-hour addition would add 14% capacity but push the heat release to 208 kW against a jacket that can remove 154 kW.

The reaction, temperatures and equipment in this series are an illustrative example. The calculations are screening estimates. They do not replace calorimetry testing, a formal hazard study or a design by a qualified engineer.

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