Managing Change
Speaking at the IIAR 2020 Online Conference and Virtual Expo, Bill Lape, a Project Director for the Risk Management Group in SCS Engineer’s Tracer Environmental Division, said that managing change is a key element of Process Safety Management (PSM) regulations.
Management of change is critical to ammonia refrigeration systems and the ability to evaluate if a change is likely to affect a facility’s ammonia refrigeration system is critical for everyone’s safety.
Lape opened his presentation by asking what regulatory bodies have to say about change management. Lape illustrated the need for change-management regulation, pointing to the Seveso directives, which the European Union wrote decades ago in response to a 7-ton dioxin release at a chemical plant that contaminated approximately seven square miles around the facility. Many other directives have been written since then that further qualify and quantify this need – specifically, the United States uses the PSM regulations (29 CFR 1910.119) and the risk management regulations (40 CFR 68.75(a)).
To understand what constitutes a change, it is important to define the term. Lape said CFR 68 defines change as the introduction of a new process, process equipment, or regulated substance, an alteration of process chemistry that results in any change to safe operating limits, or other alteration that induces a new kind of hazard.
Another important term to understand is Replacement-in-Kind. The center for chemical process safety defines this as an item that meets the design specification if one exists for the item it is replacing. This can be an identical replacement or any other alternative specifically provided for in the design specifications, as long as the alternative does not in any way adversely affect the function or the safety of the item or associated items.
This can get difficult, Lape said, and identifying what constitutes a change or a replacement in kind is important for facility managers and operators. Subtle changes in replaced equipment, such as the positioning of a valve lever, can have catastrophic impacts if operating procedures are not updated or training is not required – however, requiring these updates or training sessions is entirely dependent on the facility itself
“There is no document anywhere that’s going to say, ‘this is a replacement in kind, this is not,’” Lape said. “It’s entirely up to the individual facility and the conditions at that facility as to whether or not something is truly construed as a replacement in kind.”
“What it boils down to is that facility personnel have to be comfortable with a situation that’s deemed a replacement in kind that if they are questioned by an auditor or a regulator that they can justify it, and that justification is documented,” he said.
When looking at the history of largescale incidences in the chemical industry, a pattern begins to emerge. The root causes, Lape said, often have to do with a failure to manage change appropriately. Organizational and procedural changes were responsible for many of the notable accidents over the past 50 years.
To avoid problems, leadership needs to be mindful of any change that might affect the system’s operation. For starters, Lape said this means being aware of any changes to the chemicals being used in, on or around the system itself, such as changes in compressor oil, changes to water treatment chemicals, changes to the purity of the ammonia used, changes to anti-seize compounds purchased from suppliers and even changes in sanitation chemicals in the facility. “This is one that is often overlooked,” he said.
Operators must also be aware of any technological changes in the system. These might include transitioning from reciprocating to rotary-screw compressors, shifting from open frame pumps to hermetically sealed pumps, or moving from evaporative condensers to adiabatic condensers, using different styles of heat exchangers and changes in secondary coolants. While some of these shifts might not seem hugely significant, if they are not appropriately managed, they can create major issues.
Meaningful change can also take the form of equipment changes, such as replacements using models from different manufacturers, rebuilding or repairing components using third-party parts, or replacing condenser coils with new ones from the original equipment manufacturer.
Managing change should also be applied to procedural changes such as alterations to emergency action or response plans, facility changes like information technology networking, fire protection or cold storage racking changes, as well as personnel turnover
The key to avoiding problems, Lape said, is to first identify a change and describe it in a manner so that its nature and extent may be conveyed to a knowledgeable and competent third party. This includes the reason for the change and how it will be accomplished.
“Do this by being clear. Use simple sketches, red-lined drawings, and marked up procedures,” Lape said. “Be concise. The more words you put to it, oftentimes the harder it is to understand it. And [finally] be complete. Make sure you detail the materials, sizes, limits, and who are the stakeholders in the change. Who is going to be affected?”
On that note, Lape advised that when undergoing change, make sure that a team is assembled that represents each discipline represented in the facility; this includes operations, maintenance, engineering, environmental health and safety, and quality assurance. Each member should be knowledgeable about how the potential change might impact them specifically.
Ultimately, management of change is a process, not the form itself. A management-of-change form is used to document that process and helps ensure that no steps are overlooked, but the actual work consists of reviews and updates to equipment, personnel, and processes.
