The Divestiture Is Complete. Now the Clock Is Ticking.
For many industrial facilities, a change in ownership creates an unexpected technology challenge.
The facility may have operated successfully for decades using the parent company’s corporate systems for Management of Change (MOC), Process Hazard Analysis (PHA), Pre-Startup Safety Review (PSSR), incident management, and other Process Safety Management (PSM) activities.
Those applications may continue to function perfectly well. Unfortunately, the facility may no longer have the right to use them indefinitely.
As part of the divestiture, the former parent typically provides temporary access to selected corporate applications through a Transition Services Agreement (TSA).
That agreement establishes a limited period during which the newly independent organization must replace or assume responsibility for the systems it needs to operate.
The challenge is not simply selecting new software. It is establishing an independent PSM operating environment before access to the existing systems expires.
And unlike some corporate IT applications, PSM processes cannot simply be suspended while the transition takes place.
PSM Compliance Doesn’t Pause for a Change in Ownership
The facility’s regulatory obligations continue regardless of who owns the business or which software platform supports its operations.
Changes to equipment, processes, materials, procedures, and operating conditions must continue to be evaluated and managed. Process hazards must remain documented, corrective actions must be tracked, and critical safety information must remain available to operating personnel.
Under OSHA’s Process Safety Management standard, 29 CFR 1910.119, covered facilities must maintain the applicable PSM elements throughout the ownership transition.
This creates several immediate questions for the new organization:
- How will we manage new MOCs after the TSA expires?
- What happens to MOCs and corrective actions that are still open?
- How will employees access historical PHAs, completed MOCs, and supporting technical documentation?
- Can we establish an independent system without redesigning every existing PSM process?
- How quickly can a replacement platform be operational?
These questions must be addressed early because the answers affect both the implementation schedule and the migration strategy.
The Mistake: Treating the Transition as One Massive Migration Project
One of the greatest risks is assuming that the new PSM platform must be fully implemented and every historical record migrated before the facility can begin using it.
Consider a facility with fifteen years of historical MOCs, hundreds of PHA studies, thousands of associated documents, and numerous outstanding action items.
Reconstructing all of this information within a new application could take considerable time and effort.
The challenge becomes even greater when the original applications use proprietary databases, complex document relationships, or customized workflows.
Yet much of this information may not need to be reconstructed within the new application.
A completed MOC from ten years ago, for example, may need to remain accessible for engineering reference, regulatory compliance, or future investigations. But it does not necessarily need to be recreated as an active workflow in the replacement system.
The key is to separate the urgent requirement to establish independent PSM operations from the longer-term requirement to preserve historical information.
This distinction can fundamentally change the implementation strategy.
A Two-Track Strategy: Operational Continuity and Historical Preservation
Rather than treating the entire transition as one large migration exercise, newly independent facilities can pursue two coordinated activities.
Track 1: Establish the New PSM Operating Environment
The immediate priority is to implement the applications required to maintain essential PSM business processes.
For many facilities, Management of Change is a logical starting point because of its connections to process safety information, hazard analysis, operating procedures, training, and pre-startup reviews.
The initial implementation can focus on:
- Configuring the facility’s existing MOC lifecycle and approval requirements.
- Establishing user accounts, responsibilities, and access permissions.
- Migrating open MOCs and other active records that must continue to be processed.
- Validating essential reporting, notifications, and action tracking.
- Training personnel and preparing the system for production use.
The objective is to establish a functioning, independent operating environment without making the implementation dependent on the complete migration of historical records.
Track 2: Preserve and Transition Historical PSM Information
In parallel, the organization develops a strategy for retaining historical records from the former parent’s systems.
This includes identifying the records that must be preserved, determining how they can be extracted, and establishing an appropriate archive or repository.
Completed MOCs, historical PHA studies, incident investigations, and associated documentation may be suitable for preservation outside the active workflow environment, provided the archive meets the facility’s applicable operational, regulatory, and records-management requirements.
Special attention must be given to maintaining document relationships, metadata, approval histories, and the ability to retrieve records when needed.
The preservation strategy must also account for the TSA deadline. Necessary records should be extracted, validated, and placed under the new organization’s control before access to the former parent’s systems ends.
By separating these two activities, the facility can avoid making its new operational capability unnecessarily dependent on the complexity of its historical data.
Start with a Focused Proof of Concept
For a newly independent facility, there may be little time for a lengthy software selection and requirements-definition exercise.
However, rapidly selecting a replacement application without validating its suitability introduces its own risks.
A focused Proof of Concept (PoC) offers a practical middle ground.
Rather than attempting to document every possible requirement before beginning, the facility can configure and evaluate a representative business process using its actual operating practices.
For example, an MOC Proof of Concept can demonstrate:
- How an MOC is initiated, scoped, evaluated, approved, implemented, and closed.
- How responsibilities and action items are assigned and tracked.
- How existing facility-specific procedures and approval requirements can be accommodated.
- How users interact with the system.
- How active records and supporting documents could be migrated.
This exercise provides valuable information about both the software and the implementation process.
It also allows the facility to evaluate the vendor’s ability to respond to requirements, configure the application, resolve issues, and support the transition.
Importantly, a well-structured PoC can become the foundation for the production implementation rather than an isolated demonstration that must later be repeated.
A Practical Path to Production
A divestiture-driven PSM implementation should be structured around the separation deadline, with clearly defined priorities and milestones.
Step 1 — Confirm the Transition Window
Establish when access to the former parent’s PSM applications will end, what information can be extracted, and what assistance the former parent is obligated to provide.
Step 2 — Identify Essential PSM Processes
Determine which business processes must be operational at cutover, which active records must be transferred, and which historical information must remain accessible.
Step 3 — Configure and Validate the New Platform
Use a focused implementation or Proof of Concept to configure the essential applications, validate the business processes, and establish the required security and user access arrangements.
Step 4 — Prepare for Cutover
Migrate active records, complete user training, validate essential functionality, and establish a clear transition plan. Coordinate any final data extraction with the former parent.
Step 5 — Preserve Historical Information and Expand Capabilities
Complete the approved archival and validation activities within the TSA constraints. Additional PSM applications, integrations, reporting, and process improvements can then be introduced through a controlled expansion plan.
The sequence is important. The organization first establishes the capabilities necessary for safe, compliant operations while ensuring that the historical preservation effort is completed before the relevant access rights expire.
FACILEX®: An Alternative for Facilities Facing a TSA Deadline
Gateway Consulting Group’s FACILEX® Risk-Based Process Safety Suite provides an integrated platform for managing MOC, PHA, PSSR, incident management, corrective actions, and related PSM business processes.
For organizations facing divestiture-related deadlines, FACILEX offers several practical advantages.
Its configurable lifecycle approach allows existing facility processes to be reflected in the application without requiring extensive custom software development.
Its integrated business objects support relationships between PSM activities, reducing the need to implement multiple disconnected applications.
Gateway’s cloud-hosted deployment option can also reduce the infrastructure responsibilities that a newly independent organization would otherwise need to assume.
A focused MOC Proof of Concept can potentially be established in approximately four weeks, subject to the availability of required personnel, decisions, information, and technical prerequisites. The resulting configuration can form the basis for a subsequent production implementation.
Gateway can also assist in evaluating legacy information, identifying migration requirements, and developing an approach to historical record preservation.
The result is a transition strategy that prioritizes operational continuity while providing a path toward a broader, integrated PSM environment.
Don’t Let the TSA Deadline Determine Your PSM Future
A divestiture creates an immediate requirement for independence, but it also presents an opportunity.
Rather than simply recreating the former parent’s systems, the newly independent organization can establish a modern PSM platform tailored to its facilities, operating practices, and future requirements.
The key is to avoid allowing historical data migration to become an obstacle to establishing essential PSM capabilities.
With early planning, appropriate prioritization, and a phased implementation strategy, organizations can reduce transition risk while laying the foundation for long-term improvements.
Facing a deadline to separate your facility’s PSM applications from a former parent company?
Gateway Consulting Group can help assess your requirements, develop a practical transition strategy, and evaluate how FACILEX® can support your independent operations.
Explore the FACILEX® MOC Proof of Concept or Contact Gateway Consulting Group to discuss your transition timeline.
