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Safety and environmental standards for fuel storage sites
Final report
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173 Each site should have guidance to help its personnel to determine the difference between
like-for-like replacement and a change. This should cover items such as:
valves;
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piping and flanges;
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vessels/tanks;
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rotating machinery;
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instrumentation;
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software;
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process materials;
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operational changes;
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maintenance procedures;
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purchasing changes;
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equipment relocation.
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174 As part of its commitment to process safety leadership, UKPIA has developed guidance
and a self assessment tool for MOC.
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This provides a means by which organisations can
assess themselves against a common framework of excellence in process safety. It is specifically
intended for UKPIA members at their refinery and fuel storage facilities in the UK but is available to
non-UKPIA members involved in the fuel transfer and storage business.
175 MOC processes which align to current good practice may be further improved using
the UKPIA self-assessment tool, which provides a suitable methodology for advancing an
organisation’s MOC processes to achieve excellence in process safety.
176 The self-assessment tool is divided into five phases, as follows:
Phase 1 – Definition and scope:
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The purpose of this phase is to determine if the MOC
process has been robustly developed to address each category of change, and the roles and
responsibilities of each person involved in the change.
Phase 2 – Types of change:
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This phase is to determine if all the potential types of change
have been identified, and that any specific requirements for dealing with these changes have
been addressed. It covers the range of changes described above (including organisational
change as well as plant and process changes).
Phase 3 – Key steps:
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This phase is to determine if the MOC process has a clearly defined
structure and workflow and, where appropriate, controls in place to ensure that each change
is raised, reviewed, approved, implemented, verified, and closed in accordance with a
documented procedure.
Phase 4 – Audit:
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This phase is to determine if audits take place at appropriate intervals,
against defined criteria, and that auditing reviews the status of corrective actions. It also
considers any changes that have been made without engaging MOC.
Phase 5 – Metrics,
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training and improvement plans:
This phase is to review the strategy
for measuring the performance of MOC, through key performance indicators and, where
necessary, implementing improvements to the process.
177 The self-assessment tool uses a scoring system for each item examined, with scores ranging
from 0 (Awareness building, where practice is essentially non-existent or ad-hoc) to 4 (Optimising,
where an effective and efficient system is in place). A weighting is applied to each of the items
before aggregating into an overall score.
Summary
178 Dutyholders should ensure they have suitable guidance for their staff about what constitutes
a plant or process change, and that they have suitable arrangements in place for management of
the range of permanent, temporary, and urgent operational changes.