DSS093: Management of Change in Combustible Dust Handling Operations with Bob Petrochko

In this episode of the DustSafetyScience Podcast, Bob Petrochko, senior process safety consultant with Dustcon Solutions based out of West Palm Beach, Florida, reviews the best ways to handle management of change in combustible dust handling operations.

Bob spent over 27 years with a major chemical corporation before moving into biotech for 16 years and assuming into a process safety consultant role with Dustcon Solutions. He wrote a whitepaper titled Creating a Management of Change Process, which outlines and clarifies the ways that organizations of all sizes can effectively process all kinds of changes. In today’s episode, he answers the following questions:

What is (and isn’t) a change in dust handling industries?
Where do the management of change process requirements come from?
How should companies without an MOC program start using one?
How can managers be persuaded that an MOC program is needed?
How can documentation aspects of MOC programs best be implemented?

What is (and isn’t) a change in dust handling industries?

Bob explained that change encompasses a lot of things. Some of them are readily apparent, such as technology changes represented by major or minor process changes. Others include changes to job tasks, procedures, and process materials, which includes raw materials.

“For example, you might be operating inside of a dust handling process and you take a wall down in a large building and that creates a problem because now you have the potential of increased fugitive dust accumulation spreading out over a large area,” he said. “So that prompts evaluation of a problem like that, and then even staffing changes. People come and go. You might have an additional person added to a shift, or people removed, or positions change. So all those kinds of things have to be considered.”

He said that with equipment changes, replacement in kind is excluded from the change category. This concept is more difficult when the change involves raw materials, but not all materials adjustments need to be accompanied by a management of change (MOC).

“A lot of operations will have that defined through purchasing, through supply chain, or where R&D is inputted or tech service is inputted. What’s common in industry is that you’ll have a sheet describing the process material with specifications laid out in detail so that if (purchasing seeks a lower-priced supplier), you’ll have several manufacturers already pre-qualified that you can use without going through the MOC process.

Where do the management of change process requirements come from?

MOC process requirements appear in Chapter 8, Section 12 of the 2019 edition of NFPA 652. In addition to describing the changes that need to be managed, it states that the procedures should be written and cover the following:

The basis of the proposed change
Safety and health implications
Whether the change is permanent or temporary, excluding the authorized duration of temporary changes
Modifications to operating and maintenance procedures
Employee training requirements
Authorization requirements for the change
The results of characterization tests used to assess the dust hazard (if conducted.)

Bob said that NFPA 652 also specifies that MOC implementation is not required for replacement in kind and that design and procedures documentation should be updated to incorporate the change.

“It all makes sense. It’s pretty simple. No argument there,” he said. “The difficulty then will be in translating that into an actual process that the standard does not speak to, doesn’t need to, but that’s where the challenge rests and that’s why this whitepaper was written.”

How should companies without an MOC program start using one?

Bob recommended that companies starting at ground zero have a well-documented DHA to use as reference material.

“A DHA is going to incorporate all those critical elements that are needed. So you’ve got that as the beginning point, and over time that’ll expand and increase and you’ll have a better body of knowledge to reference, but that’s going to be your best starting point.”

To create a management of change process, three critical success factors need to be satisfied:

Management support: Without support from management, an MOC process will not go anywhere.
Technical expertise to evaluate the MOC: There needs to be people in the organization who understand the technical details of the production process, such as someone in engineering, the site manager, or a member of the maintenance team. It is also necessary to have someone who understands the applicable NFPA standards.
Communication: All stakeholders must be communicated with prior to the proposed changes so that facility management has the feedback it needs to go forward.

The next step in establishing an MOC process is to assign someone to take ownership of it. This could be the quality manager, safety manager, or member of the engineering department. Whoever it is will have to write out the procedure and ensure that it’s followed properly.

Bob recommended that companies putting together an MOC for the first time start simple.

“My best advice would be to follow the 80/20 rule. Start simple. Build your way up to the needed level of complexity that’s required over time, but don’t try to address every element in 100% detail before you roll out a process. The important part of rolling out a process is, as I described in The Critical Success Factors, getting everybody onboard to know and understand that this is coming, laying out a working procedure for starters, and then just getting it going. It will develop and get better on its own, and you don’t have to try to figure out all the details upfront. Just get something going that meets the criteria already laid out in NFPA 652.”

The next step is defining what constitutes a change. Once again, Bob advised against trying to cover everything in the beginning.

“Start out simple knowing you’re going to miss some things, and then as you go along over time, you’re naturally going to bring in more kinds of things that you recognize are changes that could impact the process and the safety aspects of it, and the process will grow on its own.”

The final step is assigning people to document the change proposal. Quality control, technical support, marketing, product management, purchasing, and R&D are all departments with personnel who can propose, communicate, and document change.

How can managers be persuaded that an MOC program is needed?

Bob conceded that persuading management to support an MOC program can be difficult and largely depends on how they view the importance of safety in the organization.

“Are they doing a DHA to check off a box, or are they doing it because they know they have a need and they really want to have a safer operation running?”

He said that at the very minimum, top management support at the site level is needed, but in some cases, buy-in from corporate staff will be necessary.

“Basically, you start at the ground level by talking to your boss and getting him or her onboard, and then in turn they go up the chain talking to their next level of management, getting that person onboard, and working all the way up. Sometimes it’s a tough process, it’s a long process, it’s an iterative process, and sometimes it’s not.”

How can documentation aspects of MOC programs best be implemented?

Bob said that thorough document completion and retention was an essential part of the MOC process.

“All this documentation, incidentally, is your body of knowledge, and you also mentioned about people coming and going, leaving. You train them, they’re gone. You got to bring somebody else in. How do you do that? How do you retain the knowledge that you need to run your process in general and also safely? You have to have it documented. It has to be documented well and has to be added to and revised as time goes on and as changes happen.”

Under process technology information, a facility handling combustible dust could include:

Dry material being handled, along with their explosibility characteristics
PFDs, general arrangement drawings, plans and elevation drawings, PNIDS
A list of SOPs containing instructions specific to maintaining combustible dust safety

He added that combustible dust safety training materials are a good place to start when evaluating a given change, as well as a list of the applicable NFPA standards. All of this information can be summarized in one digital document with direct links to other appropriate documentation. Smaller organizations that prefer hard copy paperwork can list sources or keep related printouts in the same file folder for ease of reference.

Conclusion

Bob said that he wanted to leave the podcast listeners with the understanding that establishing an MOC process is essentially simple. He described it as a two-part system that begins by writing up a two-or three-line proposal and sending it to all the stakeholder representatives across the organization.

“Get it out there so everybody can see what the thought is, and it’s simple enough that it doesn’t take a lot of time for people to take a look at it. Somebody in tech service, somebody in R&D, they’ll make a comment on it, and that’s the way to get feedback so that you can know what other things should be taken into account when considering that change.”

The next step is to drill down to the critical few functions: departments that will evaluate the change in more detail.

“That could be safety, production, or engineering. That’s how you get to filling out this form to that level of detail and going forward. So it’s something that really doesn’t take any more time than what’s necessary and you will find that anyone across the organization will be very participative in the process.”

If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Bob Petrochko directly:

Website: https://dustconsolutions.com/combustible-dust-hazard-analysis/
LinkedIn: https://www.linkedin.com/in/bob-petrochko-4a95016a/
Email: [email protected]
Cell: +1 561 339 8024

If you have questions about the contents of this or any other podcast episode, you can go to our ‘Questions from the Community’ page and submit a text message or video recording. We will then bring someone on to answer these questions in a future episode.