Temporary Management of Change: A Problem or a Necessary Part of Managing Process Safety

Temporary Management of Change projects (MoCs) seem to be the boogeyman of Process Safety Management (PSM). These temporary changes are frequently needed, but feared by operating company management, compliance groups, and lawyers. This paper explores the reasons for this aversion to temporary MoCs and proposes a paradigm shift. Instead of considering permanence as the norm, consider that everything is actually temporary. The key is designing, operating, and maintaining for the appropriate window of time. Some concerns regarding changes that have classically been referred to as temporary MoCs are valid. While other concerns are more about perception and providing easy non-compliance findings to auditors or investigators. Most alarming, many of the concerns regarding temporary MoCs may lead to worse practices and the potential to introduce more risk into the business. Policies and procedures that dictate “hard” duration limits on temporary MoCs rather than requiring appropriate review of the required duration and management of the change throughout its life cycle may introduce unintended consequences and risk into the operation. Ironically, the PSM regulation itself or interpretations of the regulation, in this circumstance, may introduce more risk into the business. The need for temporary MoCs and the risks of mismanagement of those temporary MoCs needs to be well understood by both regulatory agencies and operating companies. Regulations, policies, and procedures must drive practices that assure safe operation for any time horizon given real world impacts and constraints.