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Management of Change, Process Safety

  • 1.  Management of Change, Process Safety

    Posted 02-07-2019 12:52
    HI ! i want to ask a question related to treatment program change through MOC like boiler treatment & water treatment program.
    for me, it is inkind replacement  & there is no need to raise MOC against it. What is your opinion?

    Shahzeb Hassan ME,BE Process Engineering
    Executive Process engineer, PRL

  • 2.  RE: Management of Change, Process Safety

    Posted 02-07-2019 20:04
    Maybe I misunderstood, but what are you changing out exactly?

    Are you changing out the way you treat your boiler and water?

    A little more detail would help us give you a better response.

    Michael Saura
    Process Safety Consultant - Founder
    Saltegra Consulting LLC

  • 3.  RE: Management of Change, Process Safety

    Posted 02-07-2019 23:38
    changing the brand name like for example, we replace treatment program from GE to Nalco or vice versa.
    ingredients would be the same but tag name change.​

    Shahzeb Hassan ME,BE Process Engineering
    Executive Process engineer, PRL

  • 4.  RE: Management of Change, Process Safety

    Posted 02-08-2019 00:25
    I see. Not really. However, if you referenced the brand in other documents such as operating procedures or process manual, thosr would need change, and most likely need an MOC.

    Hope that helps.

  • 5.  RE: Management of Change, Process Safety

    Posted 02-08-2019 01:29

    Change in chemical ('equivalent') service of an operating system requires an MOC. This is an opportunity to assess any adverse impact of chemical residues to the downstream process including the related product purity or contamination. Such operating system should include boiler system as well especially when live steam is mixed with process stream.

    Besides, it is also a good practice to include MOC for the introduction of a new chemical ('non-equivalent'), or reintroduction of a chemical after an absence of two years or more. This is because there might have other process changes over the past years that warrant a re-visit to make sure.

    I hope they are helpful.

    Ng H Kiang Lucas PE, CEngS'pore
    General Manager

  • 6.  RE: Management of Change, Process Safety

    Posted 02-08-2019 03:20
    Hello Ng,

    I'd like to clarify, not only is it best practice but it is a requirement (especially if OSHA PSM or Risk Based Process Safety (RBPS)), to complete MOCs for changes that are NOT in-kind (even if the change for example is 18% to 30% aqueous ammonia solution)

    Now for equivalent chemicals with different brands,  I agree that if it's been a while since they used the previous chemical, then yes an MOC should be completed since operating conditions may have changed. But if the change is happening the same time the previous one is discontinued, and it is identical (same form, fit and function or F3) why would it need an MOC if it is exactly the same chemical with a different name?

    Can you shed some light? Maybe your referencing a specific place's law or a standard?

    Like I said, if the procedures or any other documentation will be changed due to the name, then those documentation changes would need an MOC, even if the actual chemicals are replacement in kind.


  • 7.  RE: Management of Change, Process Safety

    Posted 02-09-2019 00:27
    Mr. Lucas has pointed out very valid and effective issues.  It is very much needed to know the chemical and physical properties, dosage/volume needed  etc, of the new brand of the chemical being used. The following steps seems industry practice.

    1. Carry out Hazop for the changes being brought into the system.
    2. Adopt MOC as per the procedure laid down.
    3. Update all associated deliverables. - even if it is found only change in brand name is effective.



    [Tushar] [Poddar] [Executive Director & Principal Consultant][Singapore]

  • 8.  RE: Management of Change, Process Safety

    Posted 02-09-2019 00:42

    Shouldn't the first step to first identify what has changed between the chemicals?

    How would you understand the impacts, or determine any new hazards or operability issue if the actual change is not fully understood?

    In reality, the vendor of the new product needs to be consulted, as well as gather the SDS, and decide whether it is truly a change-in-kind. Basically, review the interchangeability of chemicals before deciding if the MOC is required (unless this is already a part of the MOC procedures).


    Michael Saura
    Process Safety Consultant - Founder
    Saltegra Consulting LLC

  • 9.  RE: Management of Change, Process Safety

    Posted 02-09-2019 02:18
    Yes, you are correct. I didn't elaborate because I considered the stand of was the only " change in "Band Name". Interchangeability of Chemical must be studied before proceeding to Hazop. 

    Thanks you

  • 10.  RE: Management of Change, Process Safety

    Posted 02-08-2019 02:06
    Nevertheless, it seems simple change.

    But, MOC must be conducted for this case since it is change for PSI (process safety information) and appropriate PHA shall be conducted.

    Moreover, it would provide great opportunity for staff to know what new hazards associated with these chemicals.   Subsequently, you need to change operational controls & philosophies.  That would also trigger for special training of relevant staff on change.

    I believe it would be helpful to build case for MOC.

    Muhammad Ali
    Process Safety Lead
    Pakistan Petroleum Limited

  • 11.  RE: Management of Change, Process Safety

    Posted 03-28-2020 10:17
    One of the reasons you would need to develop an MOC if you are doing an in kind replacement like you said would be if you are changing process chemicals and/or process technology. In my little experience, i would say do an MOC because replacing a treatment program from one to another is a form of change in technology, if i am not mistaken.

    Good luck

    Najimdeen Adewuyi
    Laboratory Specialist
    Sinclair Oil Corporation
    Sinclair WY

  • 12.  RE: Management of Change, Process Safety

    Posted 02-08-2019 08:14
    Agreed more detail is needed to ensure a proper response. While an in kind replacement doesn't require an MOC you also want to make sure there aren't any subtle changes such as a change in the material of construction the replacement unit, changes to the chemicals added to treat the water as part of the new system, etc.

    Antonio Birk EI
    Manager of Process and Packaging Compliance


  • 13.  RE: Management of Change, Process Safety

    Posted 02-08-2019 09:19
    If the loss of your utility or the failure of one or more of its components poses no hazard then I can see the system being outside the scope of the MOC process. Otherwise it needs to go through the process to determine if it's just a generic chemistry change or a different chemistry/technology. If it's different how compatible is that with the given metallurgy and process conditions.

  • 14.  RE: Management of Change, Process Safety

    Posted 02-09-2019 14:28
    As no body knows, what is the chemical composition of the patented product chemical used? products usually sale with a grade name like Non-oxidizing biocide (NX-1100) which is used specifically for cooling water treatment &  phosphate used in boiler treatment (PO 5068, N-77225) due to confidentiality of the products. All you maximum do is to go through the MSDS of the chemicals which is normally create a relevancy in products. if you are changing the dosing facility & pumps for new treatment program then yes it is acceptable that an MOC should be raised which covers all the changes & their impact on the process. If all other things are same & you are doing the in kind replacement of chemicals then there is no need to raise the MOC. For example, you are purchasing a salt through a bidding process, the formula is same NaCl  but every time you are purchasing it from different supplier then will you raise the MOC every time ? obviously Not.

    Shahzeb Hassan ME,BE Process Engineering
    Executive Process engineer, PRL

  • 15.  RE: Management of Change, Process Safety

    Posted 04-17-2019 07:07

    Dear Shahzeb

    You are absolutely correct. For Case of Boiler Material Safety Data Sheet must be known, Pressure/temperature boiler and how to work safely with the chemical product. The water quality required for your specific boiler/types of boiler is essential. As inadequate water treatment can lead to the scaling, corrosion, and fouling of the boiler and downstream equipment. Quality of BFW. HAZOP study, update the all accessory if required. If above condition not fulfill then changed the MOC. But nowadays advance treatment system is available. The most appropriate boiler feed water treatment system will help the facility avoid costly plant downtime, expensive maintenance fees, and boiler failure as a result of scaling, corrosion, and fouling of the boiler and downstream equipment.




    [Prem ] [Baboo] [DGM]
    [Dangote Fertilizer Projects]
    [Lekki] [Lagos]

  • 16.  RE: Management of Change, Process Safety

    Posted 06-11-2019 19:22
    A lesson for the future is to not be specific with the brand name of a chemical/material of construction/instrument/gasket/etc. in your operating documents OR include a list of acceptable alternative brand named chemicals in your documentation.  A little pre-planning will save you a lot of problems down the road.  This is not to say that their may be brand name materials that are required with no alternative, do your work up front and make life easier for others in the future.

    Robert Gale
    Past Chair & Director Emeritus, St. Louis Section
    Creve Coeur MO

  • 17.  RE: Management of Change, Process Safety

    Posted 06-12-2019 15:32
    yes I quiet agree with Shahzeb's  Point of view in general that we don't know much about these chemicals except for their trade names and provided MSDS. but then question arises that why are you changing the supplier? due to cost reasons or due to performance issues or some unacceptable side products which are causing metallurgy issues or and hindering the process in general. so if its due to third reason and you are changing the basic nature of chemicals to be injected than its advisable to do through MOC, as it will ensure to avoid introduction of new hazard through review and authorization process for evaluating proposed chemicals.

    Affan Sadiq PE,CEng,IENG
    Senior Process Concept Engineer

  • 18.  RE: Management of Change, Process Safety

    Posted 09-02-2019 10:50
    It is possible that OSHA might consider the two products equivalent and therefore it is possible that for purposes of PSM compliance that it would be a replacement in kind and PSM would therefore not require MOC.

    However, three important points:

    1) How would you know they're equivalent without doing the evaluation? What do OSHA reg interps say? What are the actual compositions of the products?
    2) In the end, your goal is to protect your people, your neighbors, and your plant, and that is even more important than PSM compliance. Again, you must do a professional analysis to prove the treatment programs are identical before declaring it a replacement in kind
    3) Bob Gale is absolutely correct - if either program is  determined upfront to be acceptable, the process safety information should specify this. But someone specified the vendor or manufacturer in your process safety information. That suggests that they may have felt that the vendor was important. Why did they think that? How would you know unless  you investigate?

    Finally, bear in mind that the first step in any MOC is to determine if the change is a replacement in kind. In other words, apart from changes within the safe operating window, you need to at least enter the MOC process and analyze whether the change is a replacement in kind or not. Then if RIK, you can document that and move on.

    Scott Berger CCPSP,FCCPS,FAIChE
    Scott Berger and Associates, LLC
    Washington Crossing PA

  • 19.  RE: Management of Change, Process Safety

    Posted 09-03-2019 08:42
    In a previous company I worked for, we did not have a very good MOC system or process.  However, the type of change you describe was tracked through a "Trial Plan".   Any significant change in the process, (temperature, pressure, method, chemical, even equipment or maintenance change)​ was performed using a trial plan.  It was a very simple document which would include the trial title, purpose, trial owner (usually a process engineer), timing of trial, area of trial, key performance indicators that will be tracked, expected results, review of risks, resources required, expected costs, communication plan.  And once the document was drafted, the key area owners and management would physically sign the document.....acknowledging that the trial could go forward.   When I was a young process engineer, this document helped me greatly by getting the right stake holders involved and refining the "what could go wrong" section of the document.  Since I worked in a 24/7 operation, the signed trial plan would be reviewed by each shift supervisor and their associated operator(s).   As with any type of change, communication is key.

    Now....the key word in the previous paragraph is "significant."   What is a significant change and what isn't?  From my experience, it is always better to ask around and get several opinions......including operators, maintenance people, to executive management.   Determining if it is a significant change is a team responsibility and should not be solely determined by one individual.

    Early in my career, I ran 8 trials in our process using essentially the same product (or so we thought).  But each had a different trial plan as described above.  In one particular product, they had substituted a wax in their formulation which deposited at a much lower temperature than the others.  As many people have described in this article....all of this was proprietary information to the chemical supplier at the time and we didn't know until we found deposits in our system......but because we used the trial plan concept, we could troubleshoot it to a specific supplier and then we finally discovered the root cause.   The supplier actually learned invaluable information as well and together, we improved their chemistry and our process (i.e. instead of just booting them out of the plant).

    In general, boiler feedwater treatment is directly connected to many of your most expensive assets in a manufacturing process.   The fact that you are asking for opinions on this particular example tells me that your instincts are telling you that you should track this with an MOC process.  Go with your instincts.

    John Howell PE
    Senior Process Engineer
    Fredericton NB

  • 20.  RE: Management of Change, Process Safety

    Posted 09-03-2019 17:37

    Probably new chemicals will serve exactly the same purpose of previous ones such as maintaining pH, oxygen scavenging.....etc. However, you never know what are new risks associated with this change especially if concentrations are different, dosing rates are different, ....etc.

    Such changes require MOC in general and involvement of supplier in hazards identification and risk assessment (HIRA) is fine for better clarification and understanding of risk.

    Hope that helps!


    Musallam Al-Awaid
    Process Optimization Team Leader
    Salalah Methanol Company

  • 21.  RE: Management of Change, Process Safety

    Posted 09-04-2019 00:57
    Edited by Steve Cutchen 09-04-2019 01:01
    I don't know if you are bound by OSHA PSM, but if you are, here is what Management of Change covers:

    29 C.F.R. § 1910.119(l)

    Management of change. (1) The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.

    There is a reason why you are going with a different boiler treatment & water treatment program.

    If the change in treatment program is from one vendor to another but the chemical composition and dosing methodology are the same (you are buying the exact same chemical and using it exactly the same way, only the vendor has changed... e.g., chlorine is chlorine), I would say it's not a change.

    But if you reference the vendor, or if there are any vendor-specific details in your process safety information, you have a change to modify these.

    If the treatment chemicals have a different composition at all, or if the methodology for dosing the chemical is different at all, (either of which might be your incentive) it's obviously a change and falls under MOC. You have to evaluate if the new chemical composition or the new dosing methods or controls affect the risk of boiler operation at all.

    Steve Cutchen
    US Chemical Safety Board
    Houston TX

  • 22.  RE: Management of Change, Process Safety

    Posted 09-05-2019 10:16

    Your answer is spot on, but I feel that there is one aspect you did not address directly.  As engineers we tend to focus on the process in and around the equipment.  One of the main benefits of a properly implemented MOC program is that it allows for effective communication across the entire impacted organization.  To that end, we need to make sure we step back and consider the entire process, from when and how the material gets onsite, to how the material is transported, within the facility, and then to how the material is used in the dosing process.  Many times we get better prices from different vendors because, while the compositional and physical characteristics are the same, the packaging is different.  If you have a significant change in packaging, say from 50 lb bags to 500 lb totes, there would be significant changes to how that material is moved and stored, as well as how they get the material to the equipment.  These things can have an impact on the teams working with the material, and their procedures, but it can also have an impact on the risk profile within the facility.  A spill of 50 lbs of toxic material is very different than a spill of 500 lbs.

    Just something to consider.


    Dylan Grosscup
    Sr. Process Consultant
    Missouri City, TX

  • 23.  RE: Management of Change, Process Safety

    Posted 09-05-2019 12:08
    Great addition, Dylan.

    Steve Cutchen
    US Chemical Safety Board
    Houston TX

  • 24.  RE: Management of Change, Process Safety

    Posted 09-10-2019 14:09

    Let me add one more aspect to this discussion. A change in vendor most likely results in a change in personnel that deliver the material. Changes such as this go beyond just the application of the chemical, they extend to how the chemical gets into the storage tank and what other potential hazards exist.

    David Hurban CCPSC,CSP,PE,PMP
    Principal Process Engineer
    Abbott Nutrition
    Columbus OH

  • 25.  RE: Management of Change, Process Safety

    Posted 09-06-2019 22:52
    Hi Shahzeb

    As per your question,
    In all company standards and its philosophy, we should raise a MOC if it is not inkind replacement (different specification that may cause or trigger the major accident event), if you think that your job in replacement philosophy may contribute a hazard. You should raise a MOC.

    I can’t give detail suggestion since the detail information not provided, I think the key that you should remain is “does the replacement/modification/installation may contribute to hazard/initiate major accident event?”

    You can also refer that the Boiler is categorized as SECE (Safety Environment Critical Element) or not? I think the Boiler is included to SECE, and it should put high attention to determine wether it should raise a MOC or not? Minor change or not? Need PSSR or not?

    Thank you

    Muhammad Shidqi

  • 26.  RE: Management of Change, Process Safety

    Posted 12-02-2019 16:53
    Hi Shahzeb,

    It would required to regularize the change through MOC. By doing this you will achieve the following:
    1. Update your PSI system with the new chemical specification
    2. Update a chemical interaction matrix, if you have one.
    3. Its effect on the material of construction of the boiler and downstream
    4. To decide the concentration to be used based on its effectiveness and the system requirement.

    You may also want to look at the stability of a new chemical at the boiler operating condition. May be the product gets decomposed to form any undesired product that may effect the end user assets.

    Abdul Samad Nalband
    Lead Advanced Process Control Engineer