101: Change Assessment Issue

Node Change Assessment Issue

Definition/Typical Issues

Was the change assessment improperly scoped? Did the change assessment scope fail to include all appropriate items and considerations? Did the change assessment fail to dig deep enough to identify relevant hazards and risks? Was the review abbreviated due to time requirements (e.g., an emergency change)?

Examples 

Example 1

  • A modification was made to install a new treater. A management of change assessment was completed but failed to consider the impacts on the sewage treatment system.

Example 2

  • A new oil cooler was installed. The management of change assessment did not consider the impact of the new cooler on the overall cooling system. Because many coolers had been installed without considering the impact on the overall cooling system, it was overloaded on the first hot day.

Typical Recommendations

  • Provide a list of issues that should be considered during a change assessment.
  • Develop examples of change assessments to provide guidance on the depth of analysis required during the analysis.
  • Provide detailed training to people who are assigned specific roles within the management of change (MOC) system.
  • If emergency changes are allowed, the MOC review procedure should address the definition of emergency change and the process for evaluating and authorizing the emergency change.
  • Provide descriptions of the necessary disciplines (i.e., the appropriate skills and knowledge) that should be represented for an MOC review for each type of change. Each review should include someone qualified in hazard analysis.
  • The MOC procedure should address the issue of providing back-up personnel when designated authorizers are not available.
  • Each MOC should be authorized. Sometimes the "MOC approver" function is satisfied by the MOC reviewers; sometimes the approver is different from the MOC reviewers.
  • Develop a list of responsibilities for MOC authorizers.
  • Create a system to address MOC review action items and to document their completion.
  • Confirm that temporary changes are removed from service and that conditions are properly restored to normal operations.
  • If emergency changes are permitted, the MOC review procedure should define (1) what constitutes an emergency change and (2) the process for evaluating and authorizing the emergency change.

Cross-References

Version 10 Element(s)
Node ID Node Name
74 Review LTA or Not Performed

 

Maritime Element(s)
Node ID Node Name
97 Change Review Issue
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