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MOC Process Safety

  • 1.  MOC Process Safety

    Posted 04-22-2020 15:48
    Hi, I have a question: all Change in the process required PSSR? Or only medium or large MOC?

    Best regards
    VP

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    Victor Palacios Chuy
    Enginnering Supervisor
    Procesadora De Gas Parinas
    Mancora
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  • 2.  RE: MOC Process Safety

    Posted 04-23-2020 01:25
    All the MOC's shall pass through PSSR without fail, which other wise may lead to serious incidents.

    Regards,

    Rama

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    KOTTI KUMAR
    Head Plant Operations
    INDO GERMAN PETROCHEMICALS LIMITED
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  • 3.  RE: MOC Process Safety

    Posted 04-23-2020 08:14
    Great question. The CCPS Risk Based Process Safety element, operational readiness would have us conduct a readiness review before startup, after each shutdown of the process. So the answer is likely yes.

    This is broader than the OSHA 1910.119 PSM requirement below:
    1910.119(i)(1)

    The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information



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    Jennifer Bitz, CCPSC
    Lead Process Safety Engineer/ Project Manager, CCPS
    AIChE
    League City TX
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  • 4.  RE: MOC Process Safety

    Posted 04-23-2020 10:45
    PSSR is intended to verify that the MOC was properly executed, that any MOC recommendations were adequately resolved, that any affected drawings (and other process safety information) were properly updated, that any affected procedures were updated, and that the workers have been appropriately informed/trained.  So YES, even a small MOC should be followed by a PSSR.  In fact when writing the CCPS book on Risk Based Process Safety, we changed the term from PSSR to Readiness Review, because even if there was no intended change at all, a readiness review should verify the process is safe to restart.

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    Donald Lorenzo PE
    ABS Group
    Knoxville TN
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  • 5.  RE: MOC Process Safety

    Posted 05-06-2020 02:27
    I expect the question comes from some push back on the degree of PSSR.   In refineries, PSSR after a T&I, and PSSR for any new kit are very extensive checklists with actions linking to the company central action tracking system.     A not in kind changes covered by MOC will still need some form of readiness review but not the 3-4 page checklist you use for T&I's.    Smaller forms that I have implemented for MOC-Operational Readiness review focus on (1) Has all relevant training been completed? (2), Are PSI and Operating documents updated? (3) Has communication been done?  (4) Is the work area restored to normal?      Commisioning occurs only if operations can tick off each of thoese areas.

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    Mark Hodgkinson CSP
    Albion, Brisbane QLD
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  • 6.  RE: MOC Process Safety

    Posted 05-06-2020 02:43
    Any Change in process can cause a major upset in process operation so it should go through PSSR, and also HAZOP study. Every process change require PSSR, no matter size of MOC.

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    Hiteshkumar Patel PE,CSP
    SR. ENGINEER
    Toyo Engineering India Ltd
    Surat City
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  • 7.  RE: MOC Process Safety

    Posted 30 days ago
    Hi,

    Yes. It is very well better to conduct an operational readiness check and Hazard review even for a minor MOC ( we never know where we leave a loophole). In most of the industries, they develop two types of PSSR checklist (for major changes and for minor ones).

    Regards
    Srenivas