MOC and Maintenance 1

[Eddy1988]

Hi all,

I am an young ME in a project company working on a maintenance piping packages for a local plant.

My question is whether a Management of Change (MOC) is required for the example below. This is what I found by OSHA regarding MOCs.

1910.119(l)(1)
The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.

The background is that some piping is being replaced due to corrosion. After seeing the package, it was determined that a vent at a high point of this system would be good for operations in the case of future repair work. The service is low pressure and ambient temperature hydro carbons. There are no other changes in the piping.

Would you do an MOC?

Thanks for any input,

Eddy
Lake Charles, LA

 

[MatthewL]

Eddy,

You answered your question when you quoted OSHA. You are making a change (not replacing in kind) by adding the vent, therefore, a MOC is required. Most companies (at least the ones I have worked for) have their own definition of what requires an MOC - some are more restrictive than, but all meet, the OSHA definition. For example:

Change manufacturer for a 2" 300# CS body PTFE seat 316 SS ball valve - not an MOC
Change seat to Viton - MOC required

As a general rule, if the materials of construction change, flow path, pipe diameter, etc., it is an MOC. If it is just supplier change/new version with same specifications/different manufacturer with same spec, not an MOC.

Also, process changes are also normally covered under an MOC, see the part in your quote about "technology...(and) procedures", so your vent probably changes the procedures an operator would follow (I am guessing they would have to use the vent).

Good Luck,

Matt

Matt

Quality, quantity, cost. Pick two.

 

[jte]

Eddy-

As Matt points out above, your client will define what they choose to require MOC's. I think one good rule of thumb I've seen is "If it changes anything on a P&ID*, then it requires a MOC."

*In your particular example, a vent would typically be shown on a P&ID so thus triggers an MOC. For material or valve trim changes, this would typically require a change in line class or an exception called our on the P&ID so again, an MOC would be triggered.

 

[EdStainless]

And some companies require the same process for any work. You replace in kind, they use MOC to track when that happened.

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P.E. Metallurgy, Plymouth Tube