What is the definition of an MOC for the purposes of a pipeline application?

OSHA Regulations

The Occupational Safety and Health Administration promulgated the Process safety management of highly hazardous chemicals regulations in 1992. This contains the OSHA requirement for Management of Change “MOC” (29CFR1910.119(l)).

This regulation uses the notion of a “covered process”, and each covered process is subject to MOC.  Typically any gas processing plants would be covered processes, according to §1910.119(a)(ii).  A more detailed description of covered processes is provided in Gateway’s MOC Best Practices Newsletter V4N1.

The next consideration is “what is a change?” A complete treatment of this topic can be found in Gateway’s MOC Best Practices Newsletter V4N2. There is no universal list describing what a change might be, although companies often create, say, a one-page list of things that would commonly be encountered at their sites. An excerpt from such a document follows:

What is a Change?

List which requires MOC:

  • Building modification (structural)
  • New ancillary chemical
  • New emission discharge point
  • New chemical cleaning process
  • Facility change (i.e., utilities which affects operations, water, electrical, egress)

List which does not require a MOC:

  • Changing Tuning Constants for PID loops (PLCs, discrete controllers, filters etc.)
  • Forcing PLC contacts/signals-not relating to safety-or-process. Example: Bumping motors for direction, valve check out, bumping timers for testing/checkout, etc.
  • Ladder logic changes/additions/deletions that are not related to direct process control: Examples: Code used to “debug, simulate, troubleshoot, alarms used for information only (Example: no action taken to control/change process).

This is not intended to be a comprehensive list.  it is only provided for illustrative purposes.

The third consideration is the exemption for “Replacement in Kind”. OSHA provides a simple definition:

Replacement in Kind means a replacement which satisfies the design specification [29CFR1910.119].

This just shifts the question to “what do they mean by ‘satisfies the design specification’”. Gateway’s MOC Best Practices Newsletter V3N4 goes into considerable detail on this topic. Here too, people are often looking for the “magic list” that’s a universal list of all replacements-in-kind. Such a list does not exist, but companies often create a one-page summary of replacements-in-kind that they commonly encounter. Here are some examples:

Replacement-in-Kind Examples

  • Replacing piping or equipment components with the same design, rating and material of construction, and for piping, the same routing.
  • Use of valves/fittings of same code, but different approved manufacturers.
  • Where vendor’s information is updated as required by merger, company discontinuation of parts or equipment, etc. a vendor’s identified substitution that meets the existing parts specifications will be considered a replacement in kind.

EPA Regulations

The Environmental Protection Agency promulgated the Chemical Accident Prevention Provisions [40CFR68] regulations in 1994. The wording of the EPA management of change regulations is identical to paragraph (l) of the OSHA management of change regulations.

The main difference between EPA and OSHA management of change requirements comes in the definition of “covered process”:

  • OSHA has a list of exceptions (e.g. atmospheric tanks are not a covered process according to OSHA), while EPA has a different list of exceptions,
  • The EPA notion of a covered process is simply those processes which have a threshold amount of certain chemicals, particularly hydrocarbons.

The EPA exception of greatest interest to pipeline companies is the “naturally occurring hydrocarbon mixtures” exception:

§68.115. Threshold determination.

… (b)(2)(iii) Naturally occurring hydrocarbon mixtures. Prior to entry into a natural gas processing plant or a petroleum refining process unit, regulated substances in naturally occurring hydrocarbon mixtures need not be considered when determining whether more than a threshold quantity is present at a stationary source. Naturally occurring hydrocarbon mixtures include any combination of the following: condensate, crude oil, field gas, and produced water…

This would exempt large portions of assets (i.e. anything upstream from the first processing step) from being subject to the EPA management of change requirements although gas field and gathering facilities are coming under increasing PHMSA scrutiny.

PHMSA Regulations

The Department of Transport promulgated the Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards [49CFR192.] regulations in 1970. The Pipeline and Hazardous Materials Safety Administration added the management of change provisions [49CFR192.909] in 2003.

PHMSA, appropriately, uses the notion of “covered segment” (§192.903) instead of “covered process”. A “covered segment” is determined by a risk analysis which assesses the consequences of a pipeline failure in a “high consequence area”. Considering the large asset base of most pipeline companies, it’s probable that some portion of these assets exist in high consequence areas.

Pipeline assets that are in high consequence areas must, as of Dec 17, 2004, have an integrity management program in place, as per §192.911. The integrity management program requirements are comprehensive and specifically call for a management of change program:

§192.911 What are the elements of an integrity management program?

An operator’s initial integrity management program begins with a framework and evolves into a more detailed and comprehensive integrity management program, as information is gained and incorporated into the program. An operator must make continual improvements to its program.  The initial program framework and subsequent program must, at a minimum, contain the following elements…

(k) A management of change process as outlined in ASME/ANSI B31.8S, section 11.

The reference in paragraph (k) above points to ASME/ANSI B31.8S [11], whose MOC requirements are more detailed than the OSHA and EPA regulations quoted above.