| Chemical processing enterprises
should establish policies to manage deviations from normal operations.
Systematic methods for managing change are sometimes applied to physical
alterations, such as those that occur when an interlock is bypassed, new
equipment is added, or a replacement is “not in kind.” However, the Equilon
incident underscores the need to have MOC policies that include abnormal
situations, changes to procedures, and deviations from standard operating
conditions.
For an MOC system to function effectively, field personnel need to know
how to recognize which deviations are significant enough to trigger further
review. It is essential to prepare operating procedures with well-defined
limits for process variables for all common tasks. Once onsite personnel are
trained on MOC policy and are knowledgeable about normal limits for process
variables, they can make informed judgments regarding when to apply the MOC
system.
Once a deviation is identified that triggers the MOC system, it is
management’s responsibility to gather the right people and resources to
review the situation. The skills of a multidisciplinary team may be required
to thoroughly identify potential hazards, develop protective measures, and
propose a course of action.
The Equilon incident could have been avoided if the “change” was managed
by a team experienced in hands-on operations, safety procedures, and
engineering calculations. Written procedures for cooling and emptying
partially filled drums, as recommended by an Equilon investigation team in
1996, might also have reduced the likelihood of this incident. |
The
incident underscores the need to have MOC policies that include abnormal
situations, changes to procedures, and deviations from standard operating
conditions.
The incident could have been
avoided if the “change” was managed by a team experienced in hands-on
operations, safety procedures, and engineering calculations. |
