Management of Change is an essential element of a Process Safety Management (PSM) program. The goal of PSM is to prevent fatalities and injuries, as well as property losses ranging from catastrophic to benign. Stated another way, the goal of PSM is to reduce the severity and frequency of incidents.
Incidents are often categorized using the accident pyramid. More recently, the American Petroleum Institute has used this model as the basis for API 754: Process Safety Performance Indicators for the Refining and Petrochemical Industries.
API 754 classifies incidents into four tiers: Tier 1 being the most severe and Tier 4 being the least severe. Management of Change is a Tier 4 item, and its importance derives from the fact that Tier 4 items are leading indicators. If you can optimize the Tier 4 performance, there will be an overall reduction in more severe incidents.
Examples of Tier 4 indicators that are relevant to MOC are:
- PHA follow-up item closure
- Management of Change
API 754 suggests measuring things like ensuring PHA follow-up items are completed, MOC action items are completed and the MOCs closed out, and that PSSRs are completed. Gateway’s MOC application represents all these as action items, so it’s impossible to close out the MOC without having performed all the action items. So the first concern of API 754 is addressed simply by implementing Gateway’s MOC application.
The next level of attention and detailed metrics deals with the timeliness of completing these action items. Obviously an action item that takes 30 years to complete may represent an unsafe condition for 30 years, so timeliness is important for process safety. Gateway provides a complete set of reports to permit real-time tracking of exactly what the current status is. For example, the following reports are provided:
- Reports on open MOCs
- Reports on overdue Temporary MOCs
- Reports on overdue action items, including grouping to highlight PHA follow-up items
- Reports on overdue tasks, including identification of who the task assignee(s) is/are.
An additional level of functionality, not explicitly spelled out in API 754 is the use of graphical dashboards to show statistical data and trends. E.g. how many open MOCs were there each month in 2012? Gateway can develop custom, statistical and graphical reports to client specifications, however, clients typically prefer to develop reports in-house with their own resources and preferred reporting tools.
The Next Level in MOC Metrics
Recently the Center for Chemical Process Safety has released its Guidelines for Process Safety Metrics. This book provides a comprehensive treatment of the topics of PSM metrics. For the 3 MOC-related items that API 754 identifies as leading indicators, the Guidelines book has the following number of metrics:
- PHA: 20 metrics,
- MOC: 21 metrics
- PSSR/ORR: 15 metrics
By way of summary all the data that could be used for MOC metrics, whether suggested by API 754 or the CCPS Guidelines, are made available by Gateway’s MOC application for reporting purposes.