OSHA’s 1910.119, Process Safety Management (PSM) regulations mandate that plant operators manage the hazards associated with processes using highly hazardous chemicals. A key element of PSM is the requirement for, and adherence to, a Management of Change, “MOC”, procedure. How do you reduce cycle times and effort for a business process as complex as MOC? We’ve used 5 techniques in the quest to optimize Management of Change:
- Assess the State-of-the-Art: The current state of “what is everyone doing with MOC’s?” can be catalogued from several sources:
- Review of software solutions for MOC available as commercial-off-the-shelf offerings, such as FACILEX™,
- The OSHA website contains guidance documents, i.e. “Guidelines for Management of Change for Process Safety”, Managing Process Safety Risks During Organizational Change”, and “Performing Effective Pre-Startup Safety Reviews”.
- Ideas from other fields. For instance the manufacturing field is rich with change and configuration management ideas. See for instance www.icmhq.com .
- Use Logic: Simple logical reasoning can be used to determine certain aspects of the MOC process. For instance, change initiation must occur before change close-out.
- Satisfy constraints: There may be regulatory, legal, physical or other constraints governing MOC. Obviously OSHA requirements must be satisfied, so this imposes constraints on the design of the MOC process.
- Optimize integer variables: There are many combinations of “who does what, when, in what order”. Trying these various options out in the real world is hopelessly impractical—each new process trial would require defining the process, writing procedures, training people, exercising it for, say, 100 MOC’s, and compiling the results. A much more effective method of comparing different business processes is to use simulation tools.
- Optimize real variables: There are many real variable parameters in a business process. For instance, suppose a person who hasn’t approved an MOC packet is sent an electronic reminder after ‘x’ hours. What value should ‘x’ be? Again, it’s difficult to try this in the real world and gather enough data to be statistically valid. This is another technique best accomplished using simulation.