MOC Perspectives – Risk Ranking in Management of Change
When FoCul first produced a Management of Change application back in 2000 it was very much based on the old ICI ( RIP ) model. We have been continuously evolving the MOC application since and it now includes many best practices from our customer sites. I talk to our MOC customers a lot but I thought that it would be useful to cast the net a bit wider and get more input from other practicing Engineers who also work with MOC processes day to day. There is seldom a definitive correct way to do any particular aspect of the MOC process [ which is why our app is so configurable ]. Good practice will vary between businesses, circumstances and local practices. [ See these useful books ]. Nonetheless understanding what good practices that different people are using is still very powerful.
I thought that I would have a go at writing about my perspectives on Management of Change. It may be of interest to others and trying to articulate my own thoughts here has been very useful.
Quandary 1 : When to Risk Rank an MOC ?
Firstly – why is it important to Risk Rank MOCs ?
The biggest reason for me is the “proportionality of effort” for MOCs. It is well recognised that one of the biggest dangers in MOC is people carrying out “simple” changes outside of the formal MOC process because it is too time consuming and not perceived to add value. I have seen people claim that a new fitting in stainless steel is obviously superior to the original carbon steel fitting that there is no need to do a risk assessment. We will discuss the topic of “Like for like” and “Replacement in Kind” another time – some customers do raise MOCs and some don’t. Including a risk ranking in an MOC process ensures that the appropriate stage gate processes, and suitable approvers, are involved in MOCs of different risks. High risk changes will involve more experienced people and more involved stage gate processes. Low risk changes will involve less people and simpler stage gates. This is what I mean by proportionality.
So… When to rank risks ?
As a young ICI Engineer I was brought up that a plant change needed to have a detailed risk assessment before it could be given a risk ranking. In the early days of the FoCul MOC application the Risk Ranking stage gate came after the Risk Assessment Preparation phase. The FoCul MOC application was initially set out this way so that every MOC used the same Risk Assessment process. We later introduced the idea of “Minor Mods” or “Very Low Risk Mods”. Users who felt that their MOC was very low risk could opt to complete 5 – 10 simple questions which could help confirm that the change was probably very low risk. The subsequent Risk Assessment still needed approval but that Risk Assessment process was relatively simple in nature. These very low risk changes are typically simple changes to infrastructure or simple changes to non-critical machines e.g. a different mechanical seal on a water pump. The emphasis here is on the word “very” in the phrase ”very low risk”.
Across our customers between 10% and 25% of MOCs are categorised as very low risk. This scheme works very well and some customers were keen to allocate the Risk Ranking earlier in the process for all MOCs. The benefit of this option is that the appropriate risk assessment processes can be identified sooner and the appropriate resources allocated. For changes that are high risk a HAZOP study may be used. For other changes a PHR, a “What If study” or the prompts and question sets within the FoCul MOC application itself may be used.
The bit that I struggled with is that sometimes people do not understand the true nature of a change until it has been thought about in some detail, typically during the Risk Assessment process. However the appropriate Risk Assessment process ( Hazop PHR, MOC App ) cannot be selected until the complexity of the change, and the relevant risk ranking is understood. It is a somewhat “chicken and egg” situation. In the FoCul MOC application we have addressed this by including the option for a set of prompts and questions before this early Risk Ranking step. These questions typically address things like changes to Flow, Pressure etc. Answering these brief questions helps the true nature of the change to be better understood.
Consequences of getting it wrong
The inclusion of these relatively simple questions does help but it is useful to consider what are the consequences of getting the Risk Classification wrong ? One consequence is that the risks associated with the change will not be properly assessed. This could be because the wrong Risk Assessment process ( Hazop vs PHR vs Prompts Lists ) has been used and/or because the wrong calibre of people have been involved in approving the Risk Assessment.
- The wrong Risk Assessment process leading to a poor Risk Assessment is, in my view, unlikely. If you set off to do a prompt list study rather than a HAZOP study then the process of conducting this simpler study should soon show that the change is indeed more complex than first understood and a more detailed risk assessment tool is needed. Adding a section to the end of this simpler Risk Assessment process explicitly asking if this simpler Risk Assessment process is still appropriate would be useful. If it is not appropriate then this MOC should be recycled and the Risk Ranking would be reassessed.
- The wrong people. My bigger concern would be that, in mistakenly ranking a change as lower risk, different calibres of Engineers may be responsible for the Risk Assessment approval. As a young Engineer I once misunderstood the consequences of a plant change and caused a fairly serious unsafe condition ( I shortened a dip pipe causing the gas bubbles to violently break the surface , no damage done ). A more experienced Engineer would have anticipated this.
How to reduce this as a possibility ?
There are two obvious things :
- Ensure that more than one person approves the Risk Assessment even for the Lower Risk changes. This will reduce the chances of something slipping through. A mix of disciplines would also help. In my example above even a young Process Engineer ( I am Mechanical ) would have been more likely to identify the process issue.
- Ensure that at least one well experienced Engineer is involved in the approval process. This could be the approval of the Risk Classification ( and hence the Risk Study tools used ) or the approval of the outcome of the Risk Study.
So what works for you ?
So those are my somewhat rambling thoughts on the topic of when to Risk Rank in a MOC process. What do you think ?
