PHMSA - API RP 1173 - Management of Change - Overview

This presentation takes a look at how lean principles
can be applied to:
PHMSA API RP 1173
Management of Change (MOC)
PHMSA: API RP 1173
MOC
Copyright, © 2017, Lean Compliance Consulting, Inc.—All rights reserved
Raimund Laqua, PMP, P.Eng.
Lean Compliance Consulting, Inc.
ray.laqua@leancompliance.ca
www.leancompliance.ca

WHO WE ARE AND WHAT WE DO
Lifting the weight of Regulation
Our purpose is to help you achieve better outcomes in keeping people, assets,
and the environment safe.

Companies in every sector need compliance processes to meet ever increasing
regulatory, safety, environmental, and social demands.
Traditionally, compliance is seen as an overhead or an afterthought and not
part of the business process. This is similar to where quality was in previous
years. Just as with quality, compliance needs to be designed into the process
an embedded into the day to day work practices.
This is not helped by implementing top down programs that are "heavy" in
comparison to the "lean" culture and workflows found in today's operations
and manufacturing environments.
Lean Compliance uses the LEAN mindset, tools, and techniques and applies
them to compliance resulting in sustainable processes with continuous
improvement.

Major accidents with high consequences rarely occur due to a
safety breakdown of a single activity but instead occur because of
an alignment of weaknesses across multiple activities. While safety
efforts may be applied individually to each activity more effective
safety performance is achieved when viewing the linked activities
as processes.
PHSMA RP 1173 (Goal of this Document and its Safety Management System Framework)

TOPICS
What this presentation will cover
PHMSA RP 1173
8.4 Management of Change
A LEAN APPROACH
A lean consideration of Management of Change
MOC PROCESS
RP 1173 Requirements
NEXT STEPS
Suggested next steps along your journey

MOC PIPELINE SAFETY
Brief history of Pipeline Safety Management of Change
§ 40CFR192 introduced in 1970
§ MOC 40CFR192 Introduced in 2003
§ Integrity management program based on ASME/ANSI
B31.8S[11]
§ Covered Segment defined as High Consequence Area
§ More detailed than OSHA
PHMSA – 40CFR192
§ 1910.119 introduced in 1992.
§ Process chemicals, technology, equipment, and
procedures; and, changes to facilities that affect a
covered process.
§ MOC triggered by change in design basis
§ Covered Process
§ Exception: Replacement in Kind (RIK)
OSHA – 1910.119
§ RP 1173 introduced in 2015
§ Types of changes include: technical, physical, procedural
and organizational
§ Covers all aspects of owning and operating a pipeline
§ Level of detail should be appropriate for the size of
operation and the level of risk
PHMSA – RP1173
§ 40CFR68 introduced in 1994
§ Process chemicals, technology, equipment, and
procedures; and, changes to stationary sources that
affect a covered process.
§ MOC triggered by change in design basis
§ Covered Process defined differently than OSHA
§ Exception: RIK and naturally occurring hydrocarbon
mixtures
EPA – 40CFR68

10 ESSENTIAL ELEMENTS OF RP 1173
1. Leadership and Management
Commitment
2. Stakeholder Engagement
3. Risk Management
4. Operational Controls
5. Incident Investigation, Evaluation
and Lessons Learned
MOC is part of a larger framework focused on pipeline integrity and risk reduction
6. Safety Assurance
7. Management Review and Continuous
Improvements
8. Emergency Preparedness and Response
9. Competence, Awareness and Training
10. Documentation and Record Keeping
Note:
These elements are all intended to be part of integrated risk based approach and not
seen as individual requirements.
Applying lean principles will help ensure that compliance is sustainable and remain that
way as overall maturity is advanced.

PHMSA RP 1173
Management of Change
8.4 Management of Change (MOC)
8.4.1 General
The pipeline operator shall maintain a procedure for
management of change (MOC). For the MOC, the pipeline
operator shall identify the potential risks associated with the
change and any required approvals prior to the introduction of
such changes.
8.4.2 Types of Changes
The type of changes that MOC address shall include:
1. Technical,
2. Physical,
3. Procedural, and
4. Organizational
Changes to the system shall include permanent or temporary.
The process shall incorporate planning for each of these
situations and consider the unique circumstances of each.
Note: Risk management is a central theme in PHSMA’s PSMS guideline

PHMSA RP 1173
Management of Change
8.4.3 Elements of MOC Process
A MOC process shall include the following:
1. Reason for change,
2. Authority of approving changes,
3. Analysis of implications
4. Acquisitions of required work permits
5. Documentation (of change process and the outcome
of the changes),
6. Communication of changes to affected parties
7. Time limitations
8. Qualification and training of staff.
NOTE 1: Refer to ASME B31.8S for gas transmission pipelines
and API 1163 for hazardous liquid pipelines
NOTE 2: Application of MOC may trigger use of risk assessment
to evaluate the impact of change on overall risk.
Note: These requirements can be addressed using a structured process tied to practices from supporting elements (for example:
risk management)

Managing processes requires different skills than managing
individual activities. Pipeline process management includes
determination of needs throughout the pipeline lifecycle,
provision of sufficient human and financial resources,
identification of the proper sequence of a series of activities,
monitoring and measuring the effectiveness of the activities
performed, and applying changes or corrections to those activities
as needed.
PHSMA RP 1173 (Managing the Safety of Complex Processes)

MOC PROCESS
RP 1173 requirements – Part A
INITIATION
• Change description
• Type of change: technical, physical,
procedural, organizational
• Reason for change
• Time limitations
IMPACT ANALYSIS
• Identify implications of change
• Conduct risk assessment
• Identify affected parties
APPROVAL
• Approve implementation of
requested change
DESIGN
• Identify design alternatives
• Select preferred option
PLANNING
• Develop implementation plan
• Identify required work permits
IMPLEMENTATION
• Execute
implementation plan
• Notify affected parties
• Conduct necessary
training and
qualification
INITIATION
IMPLEMEN
TATION
DESIGN
IMPACT
ANALYSIS
PLANNING APPROVAL

MOC PROCESS
RP 1173 requirements – Part B
VERIFICATION
• Inspect work
• Conduct Pre-startup Safety Review
CLOSE-OUT
• Document change process and outcome of changes
• Update affected documents and records
• Conduct lessons learned review
VERIFICATION CLOSE OUT
Summary
§ RP 1173 requirements can be
addressed by using a structured
process and applying lean principles to
ensure the right steps get down at the
right time.
§ May require additional tools if not
already part of current process:
§ Risk Identification, Assessment,
and Treatment
§ Impact Assessment
§ Stakeholder Communications
§ Lessons Learned Register

Safe and effective pipeline operation requires awareness and
management of numerous linked activities. Major accidents rarely
occur due to a safety breakdown of a single activity, but rather an
alignment of weaknesses across multiple activities that enable
compound conditions resulting in events of high consequences.
PHSMA RP 1173 (Managing the Safety of Complex Processes)

A LEAN APPROACH
Considerations for leaner processes and data management
MOC PROCESS
The MOC process needed to support RP 1173 can benefit from following a life cycle
approach to ensure that all required steps are completed and coordinated to happen
at the right time. Eliminating non-value added activities is an important consideration
to ensure that both data and process activities produce what is needed to safely
implement the change.
STAKEHOLDER ENGAGEMENT
Pipeline operators need to maintain a process to communicate and engage
stakeholders. This is particularly important when changes are made affecting either
internal or external stakeholders including notification to regulatory bodies.
Identifying and tracking stakeholder communications should be part of the MOC
process to help ensure that all affected stakeholders are kept informed. Care should
be taken not to over communicate and add to organizational waste.

A LEAN APPROACH
RISK MANAGEMENT
The identification and treatment of critical risks is crucial to keeping everyone
including the environment safe. During the MOC process it is essential to identify
any new risks or hazards introduced either during or after the change has been
completed.
Risk assessment and treatment is an important way to ensure that the appropriate
level of rigor is applied to each MOC.
INCIDENT INVESTIGATION, EVALUATION, AND LESSONS
LEARNED
Learning from prior MOCs is an important part of an effective improvement process.
Lessons learned are often included in risk assessments and control processes to help
limit impacts or reduce the likelihood of anticipated risk.
Introducing steps to conduct a lessons learned review as part of each MOC is
important to support continuous improvement towards a leaner process.

A LEAN APPROACH
SAFETY ASSURANCE
Data and documents from each step in the MOC process provide useful information
to evaluate not only the effectiveness of the MOC process but also how risks can be
reduced or avoided in the future.
The MOC process should include measures to improve overall pipeline safety
performance.
DOCUMENTATION AND RECORD KEEPING
Every PSM system requires that documents and records be kept to capture the
planned work and what was actually performed.
In addition, the MOC process should also manage changes to critical procedures to
ensure the correct steps and information are communicated to keep everyone safe
and operations running smoothly.
Updating documents in a timely matter and making them easily accessible will help to
reduce delays and improve overall process times.

Adopting and implementing a safety management system will
strengthen the safety culture of an organization. Leaders,
managers, and employees acting to make safety performance and
risk reduction decisions over time will improve pipeline safety as a
value, thereby strengthening the safety culture of an organization.
PHSMA RP 1173 (Goal of this Document and its Safety Management System Framework)

§ Identify stakeholder (or customer)
value
§ Map out the process and data flow
§ Identify and remove areas of waste
§ Identify and address compliance
gaps
§ Streamline work flow and Establish
Pull
§ Create implementation plan and
implement your next step
NEXT STEPS
Map value stream and identify areas of process and data waste
Map
Value
Stream
Remove
Waste
Address
Compliance
Streamline
Flow
Implement
Next Step
Identify
Value

NEXT STEPS
Plan for continuous improvement
DO
CHECK
PLAN
ACT
Identify areas for improvement and
create prioritized improvement
roadmap.
Implement highest priority
improvement tasks.
Verify that improvements
are realized.
Continue to identify areas of
improvement.

NEXT STEPS
Implement Maturity Model to support RP 1173
Level 1
• No requirements.
Every organization
automatically is at this
maturity level
Level 2
• MOCs will be
managed. Similar
MOCs can be
successfully repeated.
Level 3
• MOCs will follow a
standardized process
Level 4
• A statistical process
control will be
implemented
Level 5
• Routines and working
methods are
improved according to
statistical process
control
PHMSA 1173 - 10.7 Evaluation of Maturity
The pipeline operator shall establish a method to evaluate the
maturity of its pipeline safety management system

Email us at: info@leancompliance.ca

PHMSA - API RP 1173 - Management of Change - Overview

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