While your MOC program may be in compliance with the regs, its processes may not be as efficient as they could be.
Over the past 17 years, Management of Change (MOC) has received increased attention at chemical plants and refineries due to the promulgation of new OSHA regulations. Officially designated 29CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals, the OSHA PSM regulations state that any time a critical component in an oil or chemical plant changes, a formal MOC program is required to ensure that the proposed change is made safely.
However, recent analysis conducted by Gateway Consulting Group, a specialist in the design and implementation of enterprise content management (ECM) solutions for chemical and petrochemical plant environments, notes that while plant owners are in compliance with OSHA regulations, their MOC processes are not necessarily efficient. [Ref. 1]
Evidence of poor efficiency includes:
- Long cycle times for MOC closure;
- The need for, and hiring of, temporary staff to “look after the MOC paperwork” prior to and during turnarounds;
- People being asked to review documents on which they’ve previously signed off;
- Any person who is asked to sign a document or form, to signify that they’ve been notified rather than to approve the document.
These problems exist whether the MOC system is entirely on paper, entirely electronic or a hybrid.
“When OSHA issued the regulations in 1992, I took a very hard look at all of the information management that needed to take place in order to comply with the PSM regulations. I counted over 101 information-items and document types,” says Dr. Rainer Hoff, Gateway’s president. “If you are operating a small gas plant in a remote location with less than 10,000 documents, then probably a paper-based system is adequate. But, if you are operating a larger plant with potentially 200,000+ drawings and 10 million+ pages of documents, then it gets to be a little more onerous. The volume of information to comply with PSM is great and doing it with paper can be unwieldy. Electronic systems offer an advantage.”
According to Hoff, to really excel at MOCs, an organization needs an ECM system with an MOC application. The necessary capabilities include: a repository for managing all the plant documentation including drawings and equipment files; a records management function to ensure that all data in the repository is compliant with applicable regulations and standards; an MOC application that manages all the data needed to execute the MOC; and, an electronic signature capability.
Although an electronic MOC system does not necessarily need to handle documents and records management, ensuring that documents are updated appropriately and managed as records is a natural extension of the system. Benefits will include reduction of both the backlog on managing the revisions of those documents, and of errors due to documents not being kept accurately up to date. Having all MOC-related content accessible in a single ECM repository provides full visibility and transparency should OSHA arrive to review a particular MOC.
MOC is the largest business process for a facility. Operators are constantly searching for ways to conduct the work more efficiently to reduce costs in terms of time, human resources, money spent on the process and the consequences, and safety, environmental and reliability implications. Hoff points to three major types of MOC applications in the marketplace today:
- MOC Tracking Applications. These usually consist of a database and a number of forms. They track header data about the MOC (e.g., number, date created, where in the plant the change is located) and some status information about the MOC (e.g., who has it, who has already approved it). Some reports also can be generated. MOC tracking applications are very resource-intensive since a person must be designated as the administrator for the MOCs. MOC tracking applications do not automate any part of the business process.
- Traditional Workflow-Based Applications. These applications are programmed using traditional, transaction- oriented, workflow tools. Each step is identified, which means the person creating the workflow must know how many steps there are and who is supposed to perform them. This can be problematic since MOCs have such huge diversity: up front you never know what has to be done on a given MOC, what documents have to be updated and who the approvers are going to be. When traditional workflow tools are used to model this level of uncertainty, the workflows become extremely complex. Furthermore, traditional workflows have a strong notion of “flow”—when one task is finished the next one begins. That forces an excessive amount of sequencing on the workflow. Forced sequences slow down the entire process, making the approval process unacceptably long.
- State-Based MOC Applications. In these applications, the MOC lifecycle is broken into various states—Initiation, Classification, Approval, Mechanical Integrity, etc. During a state, the application is quite flexible since tasks can be added or removed and approvers can be added or removed (subject to certain rules). This provides the fastest and most flexible method for completing the work of MOCs. The decisions regarding which documents need to be updated, which tasks need to be completed and who the approvers should be (for any state) are driven by a set of rules. The rule set is created and enhanced without any programming (which would be the case with the traditional workflows). As a result, it’s more convenient, quicker and less expensive than other approaches.
Over the last two years, Dr. Hoff quantitatively analyzed MOC processes at over a dozen chemical and petrochemical facilities in the United States. The resulting statistics highlight bottlenecks, identify areas for improvement and, most importantly, quantify the improvements that will result from changes in the process. [Ref. 2] This research was done to complement the data he had from conducting over 20 plant-based electronic document management projects.
“The Gateway MOC best practices research is based on the notion that “best” can’t be “best” until it’s proven to be “best.” In order to prove something is “best,” you need to have objective criteria. In other words, we have to measure something, such as cycle time, cost, or some combination thereof,” says Hoff. “Due to practical limitations, we couldn’t go to a company and try out many different kinds of MOC processes, but we could simulate many different kinds of MOC processes. We used the Petri-Net method for simulating MOCs. This is a very powerful and flexible tool, and we haven’t encountered a process yet that can’t be modeled with Petri-Nets.”
To date, Hoff has run over 100 million iterations of simulations of different aspects of MOC and has a good statistical base upon which to draw conclusions about what is “best.” The kinds of questions that get answered with Petri-Nets are: ‘Where are the process bottlenecks?’ ‘Where are more/fewer resources needed?’ ‘How can cycle times be reduced?’ and, ‘How much does it cost to reduce cycle times?’ among others.
Approvals are one area where an electronic MOC system can provide great benefits. Gateway’s research highlights the fact that process improvements, defined by reduced cycle times, can be effected with the following types of techniques:
- Using electronic approvals rather than collecting signatures on a paper form;
- Conducting approvals in parallel as much as possible; serial approvals take much longer;
- Having the system send out reminders when approvals are overdue;
- Expediting approvals when they are greatly overdue;
- Ensuring that each approver has delegated someone to act on his/her behalf, in the event that the approver is absent (i.e. away from the plant);
- Training people to respond to electronic requests for action, rather than ignoring them
- Only using approvers who will contribute knowledge to the process; everyone else should simply be on the notification list, not on the approval list.
“Surprisingly, and this was revealed by the simulations, the second largest benefit of electronic MOCs is that the MOC packets don’t get lost. Lost MOC packets are a big problem in the paper MOC world, and they cost a huge amount of time and resources. Electronic MOCs do not get lost, so this problem goes away,” adds Hoff.
Gateway’s analysis suggests that a chemical plant or petroleum refinery can save significantly on a typical MOC using an electronic system. “Reducing the cycle time to do a routine MOC from 40 days down to 20 days is entirely reasonable,” says Hoff. “Instead of requiring 30 man-hours to process, it now takes only 20 man-hours. Based on our analysis, this reduced effort amounts to $1000 savings per MOC. So, if a company does 500–800 MOCs per year, this would amount to a potential savings of $500,000–$800,000 per year.”
But, these savings are only half the picture. Quite often, to do a change, a plant or refinery must turn around a unit. A crude unit at a refinery could process about 150,000 barrels of crude per day. With current gas prices and the price of oil, that can amount to about $15 million worth of crude that gets processed per day. So if a refinery needs to shut down a crude unit for a day, it could lose perhaps $1 million in profit simply because the unit shut down. If the MOC paperwork is stalled, overdue or late, it will mean delays in starting up the unit again. With an ECM system in place, when a turnaround occurs, companies will have a much greater ability to predict when the changes are going to be done and avoid delays in starting up again. MT
Chris Vassalotti is responsible for business development and solution initiatives for Open Text in the areas of Energy, Chemical, Utilities, and Engineering. He has been building and delivering enterprise wide applications for engineering related industries for over 10 years. References 1. “Management of Change Best Practices,” White Paper by Rainer Hoff, Ph.D., P.Eng., president of Gateway Consulting Group, Inc., May 2007 2. Ibid.
HOVENSA, a joint venture between a subsidiary of Hess Corporation and a subsidiary of Petroleos de Venezuela, S.A. (PDVSA), operates a world-class merchant refinery in St Croix, U.S. Virgin Islands. One of the most modern refineries in the U.S., HOVENSA has a crude oil processing capacity of 500,000 barrels per day. It is one of the largest facilities of its kind in the world.
HOVENSA engaged Gateway Consulting Group to conduct a thorough study of their information management requirements; assist in the vendor RFP and product evaluation support; and aid in the planning and design of an ECM solution for the refinery. Working with a cross section of people from maintenance and engineering areas to develop their requirements, Gateway identified a number of business processes where the company could increase efficiencies with an ECM system. The processes range from MOC and Material Safety Data Sheet management, to drawing management with CAD integration, work permit records, and accounts payable processing.
Following an extensive review, HOVENSA selected Open Text’s Livelink ECM as the corporate platform for its electronic Document Management, Workflow and Records Management features.
“We had several requirements. One was document management: making documents easy to find. We also wanted a way to control who could update the documents and be able to keep track of the revision history and audit trails,” says Bob Guilford, Application Development Leader at HOVENSA. “With paper-based systems, it’s often difficult to find and trust information. You may have the current version or an older version, the version history isn’t known, and it may be time-consuming to find a document.”
Document and records management was one major focus for HOVENSA. Records management ensures compliance and reduces risk by enabling the full lifecycle management of all corporate information. The other driver was finding a better way to manage workflow processes. “Paper based workflows are not very efficient. Paperwork can get lost and it may sit on desks. Electronic workflows can be tracked with audit trails and can send out automatic email reminders,” says Guilford. “With electronic workflows we can streamline many of our business processes—everything from expense reports to vacation requests—our standard business processes that have historically been done by paper based forms.”
Guilford says the first paper-based process to go electronic will be MOCs and Incident Investigations. “MOC is probably the most rapid payout so we’re focusing on that one first.” The Process Safety Management Group identified several issues with its paper based MOC and Incident Investigation processes that would benefit from an electronic MOC solution: the paper based process requires significant, tedious follow up work by the engineering staff. Another issue is that paper approvals are all-inclusive, meaning the MOC package must be kept complete and intact—leading to unnecessary work and delays as well as inconsistent usage.
“A significant problem with paper workflow is that it goes to one desk at a time,” says Guilford. “By making it electronic, it allows multiple people to work concurrently. For example, if there are approvals needed from three people, they can all be notified and begin the work on approvals at the same time since the electronic package will be accessible by everyone. Also, steps can’t be taken out of order. There’s an audit trail of who approves what and when. Standard-ized work processes will keep us consistent and improve compliance quality.”
Open Text teamed up with Gateway and HOVENSA to develop its Livelink ECM – MOC solution based on Gateway’s MOC best practices. The Livelink Plant Compliance software offers companies a configurable “Plant Compliance Workspace” for the MOCs, Incidents, and Action Items. Building on the core strength of content management and business process automation, the solution provides all the key components, including the Plant Structure browser, simple initiation of MOCs, the ability to report on these topics using Web reports or business intelligence (BI) tools as well as document management, audit ability and business process management (BPM) capabilities. The metrics based reporting allows workflow issues to be identified and resolved, speeding up the cycle times.
Within the Plant Compliance workspace, organizations can be grouped into sites and site-specific divisions. An asset-based system, it represents all the equipment in the plant, typically by a hierarchy of Area, Unit and then individual pieces of equipment within that unit. Companies also can drill down even further to parts and components, etc. Users can go to any level on the plant structure and see all of the MOCs that have been generated. For example, once at the unit level, users can see all the different pieces of equipment that have an MOC in a particular unit.
All of the content associated with an MOC, such as equipment manuals, process and instrumentation diagrams, CAD drawings, email communication, etc., is stored in a central ECM repository and can be tied back to the physical assets of the plant. This ensures that all documentation that represents the physical condition of the plant is readily accessible for risk management and compliance purposes.
“In our case, we have one site—HOVENSA—and it’s organized by Areas, each consisting of several units,” says Guilford. “The plant structure serves several purposes. Equipment or locations to be changed can be selected on the MOC entry screen. This allows reporting based upon consistent equipment names. Livelink imports the plant hierarchy from our Maintenance System stored in SAP (which will allow future SAP system linkages). Also, default workflow roles can be assigned based on the Area or Unit being changed.”
Guilford adds: “The solution is very flexible in that we can assign our own names to the fields on the entry screens; we can write our own ‘mouse-over’ messages with instructions for the user; we can add fields if we want additional fields for reporting purposes. It’s highly configurable, which is an added benefit.”
‘Fast Track’ MOCs allow a template workflow to be copied for the more common cases where the same type of change may be repeated many times. This enables common activities to be handled efficiently and ensures better consistency. Demonstrating the immediate benefits that an electronic MOC system can offer for these common occurrences is an effective way to gain user adoption when rolling out the new system. “I think our users will gravitate toward the new MOC system pretty quickly,” says Guilford. “The paper-based process had a lot of disadvantages. The electronic system will allow our engineers to do engineering work, not paperwork.”