Management of Change – Capital Projects and Turnarounds
There are often multiple business processes taking place at the same time in a refinery or chemical plant. Major business processes include:
- (large) capital projects,
- small projects,
and each of these interacts with MOC’s in some way. It’s important to position these business processes appropriately, so that there are no gaps (“I thought you were doing that”, “No, YOU were supposed to do that”) at there is no duplication of effort. We’ll take a closer look at each of these processes, in order to determine the best practice.
Taking a “closer look” may be easier said than done, since each of the aforementioned business processes is quite complex, in its own right. Comparing and contrasting them may be intractable. In order to manage the complexity of these comparisons, it’s necessary to reduce each of process to its simplest form. For MOC’s we’ll introduce the notion of “Extreme MOCs”.
The notion of “extreme” has become more prominent nowadays, and examples from popular culture are given in Table 1. Although Extreme Fighting is used as the competitive sports example, there are indeed many sports which have evolved an “extreme” format. Note that there’s a recurring theme of taking some aspect of the activity to the limit.
|Extreme Makeover: Home Edition™||Home construction with a minimum of time|
|Extreme Fighting||Full contact combat sport with a minimum of rules.|
|Extreme Programming||Development process with a minimum of time between releases|
|Extreme Snowboarding||Snowboarding on steep mountainsides with a minimum of conveniences like trails, lifts and patrols.|
Table 1. Extreme activities in modern culture.
An interesting thought experiment would be to see if there is an extreme MOC format. Let’s coin the acronym “xMOC” for extreme MOC. An xMOC would contain the absolute bare minimum of elements. Figure 1shows the OSHA 1910.119 wording for Management of Change. Paragraph (l)(1) indicates that a procedure must be in place to manage changes, which is a governing requirement. Each MOC instance must have the nine essential elements highlighted in the figure.
An xMOC form could be created from these 9 elements, as indicated in Figure 2. Just as Extreme Fighting and be hazardous to your health, and Extreme Snowboarding is potentially life-threatening, using the xMOC form in a real company has all kinds of risks associated with it. We’ve only developed the xMOC form as a thought experiment, since it will help illustrate certain points discussed in the following sections.
(Large) Capital Projects
Introduction to Large Projects
Refineries and chemical plants are often expanded or upgraded via large capital projects. These projects typically range from $1 million to $1 billion in today’s currency.
The nomenclature is sometimes confusing. At most plants, these are called “capital projects”. True, but the word “capital” refers to an accounting designation. The important attribute of these projects, from a business process standpoint, is that they are large. We could call them “large capital projects”, but let’s simplify and just call them “large projects”.
A great deal has been written about how to effectively manage large projects. The Project Management Institute is a professional organization and advocacy group for project management, has many resources available on their website: www.pmi.org, and promotes the notion of a “Project Management Body of Knowledge1”. Ref.  begins with a generic 3 phase model: “Initial”, “Intermediate” and “Final”. These phases are then fleshed out with details more common to MOC, including Initiation, Planning and Execution.
Project Management Institute, Inc., A Guide to the Project Management Body of Knowledge, Third Edition, Project Management Institute, Inc., Newtown Square, PA, 2004.
Figure 1. Annotated Management of Change regulation, showing the 9 essential elements.
Figure 2. Extreme MOC form.
Another resource, in this domain is Kepner‑Tregoe, Inc. which provides consulting services and training in project management. Kepner-Tregoe employees, including the eponymous Messrs. Kepner and Tregoe, have authored books on the topic of project management1.
The Kepner-Tregoe, “KT”, model represents a project in 3 large phases. Note that KT do not use the word “capital” to label the phases.
Longman, A., and Mullins, J., The Rational Project Manager, John Wiley & Sons, New Jersey, 2005.
Figure 3. The 3 phases in the Kepner-Tregoe project model.
Most large organizations understand the need for a systematic project process, and have taken the KT or similar model and adapted it for local usage. Figure 4 shows how Company A has decomposed the 3 phases of the KT model, into 7 lifecycle states for large projects; Company B uses 8 states to achieve the same goals. Note also that, while “Initiation” and “Close-Out” are widely accepted as the names for start and finish, the intermediate state names are different, even though the work is very similar.
Figure 4. Adaptations of the KT model by various companies.
It turns out, that the relationship between the MOC process and the Large Projects process can be illustrated at the phase level. This avoids the problem of trying to identify which Large Project lifecycle is the “correct” one and which set of terminology is preferred.
The Relationship between Large Projects and MOCs
A large project process generally requires the performance of a full Process Hazards Analysis. So, it looks like essential element 2 is already addressed by the large project process, so there’s no need to redo it for MOC purposes.
The design of a large project would, if relevant, consider how current operations might be impacted, so essential element 3 is addressed.
Project management has time as one it’s three critical variables (scope and cost being the other two), so essential element 4 is addressed.
A large project generally has a large budget requiring multiple approvals to cover the technical and financial aspects of the project. So, essential element 5 is also addressed.
Informing affected persons, training, updating and releasing documentation into productive use are all tasks normally conducted during a large project. So, essential elements 6, 7, 8 and 9 are addressed by a major project.
Figure 5. How the essential MOC elements are addressed in a large project.
It appears from Figure 5 that all of the essential MOC elements are already covered by the Large Project process. So if an MOC were initiated to “cover” a large project, the role of the MOC would simply be to record, in some concise manner, that all the essential elements of the MOC regulations have been addressed.
As shown in Figure 6, the large project controls the scope of the MOC and controls the timing of the MOC, and from Figure 5 the “real” work is already covered by the large project process itself. Since the MOC is entirely dependent on the large project, we can call the MOC a passive process and the large project an active process. Therefore, we can arrive at the interesting conclusion that:
“In a large project environment, the MOC process is generally a passive process, focused on quality assurance concerns”.
There may be projects related to, but not contained by, the large project and these related projects may be active (instead of simply quality assurance) and independent, but these will be discussed in the section on “Stand-Alone MOCs”.