Dr. Rainer Hoff is a recognized authority on the topic of Management of Change (MOC). Several of his presentations from AIChE Global Congress on Process Safety are provided below.
Companies are looking to improve their process hazard analysis practices to reduce costs and modernize their PHA tools. In this video, Gateway presents the commonsense requirements for a PHA solution based on extensive research and experience gained from implementing process safety systems over the last several decades.
Since ChatGPT's public debut in late 2022, the Process Safety Management (PSM) community has shown increasing interest in Artificial Intelligence (AI). AI is being used to capture company data and leverage industry knowledge. While Machine Learning (ML) applications in process safety have been explored, the rise of large language models with chat-style interfaces has made AI accessible to non-experts. Over the past year, the “AI-PSM” LinkedIn group has facilitated discussions among professionals, analyzed using Prof. Thomas Malone’s “4 Roles of AI” framework. This framework helps address the tension between efficiency gains and safety risks associated with AI adoption in process safety. The paper explores AI sentiments within the AI-PSM group, considering challenges like mathematical problem-solving and error handling.
Artifical Intelligence is the biggest new technology humanity has discovered in years. Are you ready for the impact that AI will have on Process Safety Management? This presentation targets what can be done using the public ChatGPT, without training the AI with your company's proprietary or confidential data. All the examples are Process Safety oriented for Management of Change (MOC).
This presentation outlines a practical approach to risk management, focusing on process safety management within industrial settings. It covers the utilization of Gateway's flagship product, FACILEX®, for creating and managing a Risk Register and tracking risk metrics, specifically using PowerBI for visualization. The presentation delves into categorizing risks as either specific (such as equipment or safety risks) or general risks, detailing their management life cycles from identification to ongoing monitoring. It also discusses various industry and regulatory initiatives like ISO 31000, RBPS, and API 1173, emphasizing their importance in risk management. Facility risks are classified into program-specific and Risk Register items, with a procedural approach recommended for comprehensive risk management. The document extensively showcases how FACILEX® facilitates the detailed process of risk identification, treatment, and monitoring, including examples and practical uses of the software in managing risks effectively.
In this presentation Dr. Rainer Hoff, Founder of Gateway Consulting Group, Inc. provides strategies for implementing an Incident Investigation and Reporting process to establish root causes and prevent recurrence. He looks at solutions capable of managing both Severity Rankings for API-754 - Loss of Primary Containment (LOPC) incidents and CCPS which includes non-LOPC incidents. The discussion targets process improvement opportunities through the use of optional process lifecycles: a detailed investigation or a simple report based on a triage rules. Many ideas are provided on how to handle Follow-up Items such as:Engineering and design changes, Procedure and process modification Training and communication, Management and organizational changes Maintenance and inspection enhacements, etc. The presentation provides some excellent guidance on Data Visualization: Excel, Power BI and ChatGPT.
The presentation delves into the core elements of Risk-Based Process Safety (RBPS), illustrating how they align with and expand upon traditional process safety practices. It explores the integration of RBPS with related standards such as API Recommended Practice 1173 and IEC-61511, as well as emerging considerations like cybersecurity and functional safety management. Moreover, it examines the intersection between ESG and process safety, highlighting the synergies between the two domains in enhancing reputation, attracting investors, and reducing business risks.
This document outlines the concept of "Replacement in Kind" (RIK) in the context of OSHA’s Process Safety Management (PSM) regulations, emphasizing it as an efficient approach to Management of Change (MOC) by allowing certain replacements that meet original design specifications to bypass the formal MOC process. This approach is cost-effective as it avoids the extensive requirements typically associated with MOC, provided that the replacement aligns precisely with the original design intent, as outlined in OSHA’s definition of RIK. The document addresses challenges related to missing or incomplete design specifications, explaining three primary assumptions that guide RIK decisions in such cases: the "grandfathering" assumption, which allows identical part replacements; the "generic" assumption, which permits parts from alternative manufacturers if they meet the same operational criteria; and reliance on Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) where applicable.
This document discusses the criteria and regulatory requirements for determining when a Management of Change (MOC) is necessary, as mandated by OSHA's Process Safety Management (PSM) standards (1910.119). An MOC is required if a proposed activity within a covered process constitutes a change that is not simply a replacement-in-kind. Understanding whether a process is "covered" is essential, as processes that do not fall under PSM regulations avoid associated compliance costs. Covered processes involve either specified quantities of hazardous chemicals or significant quantities of flammable substances, with exemptions for retail, oil, gas, and remote facilities. The document examines key terms, including "process," which encompasses any activity involving hazardous chemicals. The PSM standard applies broadly to interconnected and closely located components that could contribute to or exacerbate a hazardous chemical release. OSHA interpretations clarify ambiguities in applying PSM to specific cases, such as differentiating between manufacturing and using explosive devices. Legal interpretations have further refined PSM applications, with a focus on OSHA’s intent to prioritize safety over semantic distinctions, underscoring the importance of correctly defining covered processes for effective safety management.
This document examines what a change is in the context of the OSHA PSM regulation, which specifically lists asset changes (process chemicals, technology of the process, equipment and facilities) as well as procedures. Furthermore, there is an evolving consensus that organizational changes are also changes that should be managed by MOC. And finally, the notion of impacts of systemic change is introduced. MOC almost always requires changes to process safety information. A thorough review of PSI is presented, within the practical limitation that it’s impossible to know what every company calls every kind of document.
Changes to facilities always involve BOTH an MOC and a “work process”. Some sites emphasize the work process aspects, driven by the existence of Enterprise Resources Planning systems, and handle the MOC essential elements poorly. Other sites burden the MOC process with many capital-projects aspects and create a very complex change management environment. Surely there must be a happy medium? This paper analyzes data from case studies from actual implementation projects, identifies gaps and makes recommendations on the best practice for conjoining MOC and other work processes.
This paper focuses on an Organizational Management of Change (OMOC) initiative implemented at a large energy company with PSM covered processes. It describes the risks associated with both personnel and structural changes and the mitigation strategies employed.
This paper focuses on the challenges of improving the MOC business process at small sites. An MOC improvement initiative generally involves improving the MOC business process, and then assisting with some form of technological automation.
This paper conducts a critical review of the various techniques for managing work-in-process documentation for MOCs and presents specific recommendations on best practices for MOC-WIP document management. Examples from actual installed systems are presented.
This paper describes conceptual and computational models of the MOC business process, which provide a platform for quantitative assessments of various parameters such as effort, duration, cost, and so on. An MOC Standard Model is developed and validated. This provides a benchmark against which MOC alternatives can be measured. The characteristics of the MOC Standard Model provide guidance for policy decisions that are immediately applicable by practitioners wishing to create or improve their MOC processes.
One of the key features of electronic systems is the ability to send out reminders when an approval has not been completed in the expected time. This white paper discusses how frequently reminders be sent out.
This white paper discusses the benefits of taking an integrated approach that combines MOC process & MOC product analysis.
This white paper discusses several important issues regarding the management of MOC’s as corporate records. Key issues include:retention periods, electronic MOC systems, file formats and planning for obsolescence.
In this white paper Dr. Rainer Hoff looks at MOC Data Content. An MOC has a minimum amount of information that is needed to satisfy regulators. But, an MOC should contain much more data, in order to make the change management process efficient.
In this white paper Dr. Rainer Hoff introduces the importance of the MOC Lifecycle in the application of Best Practices. The author provides several examples for consideration including: Full-Permanent/Temporary, Short-Permanent/Temporary, Emergency, Urgent and Follow-up.
This white paper introduces Dr. Rainer Hoff’s research in the domain of establishing the best practice for Management of Change (MOC). The author has condensed data collected at numerous sites and reviewed dozens of existing MOC practices.
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