Wyn032 PDF

Title: MANAGEMENT OF CHANGE PROCEDURE -
WYANDOTTE
Site Function: Ecology, Health & Safety

Procedure No.: WYN032.075 Page: 1 of 21
Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

Preparer: Owner: Approver:
EHS Team Member EHS Team Leader OHMICAN Hub Manager
Tom Ozimek Tom Ozimek Peter Dulik
Revision History
Revision Revision
Nature of Change
Date Number
12/01/11 New New procedure to establish Wyandotte Site EHS MOC Process.
Procedure revised based on input from MOC workgroup as well as
Changes made with Corporate Database in June 2015. Additional
6/3/16 1 tools provided along with defined roles and responsibilities. Revisions
to site standard align with changes to Change Manager Database as
well as identified areas for improvement based on gap analysis.
The Electronic Document is Controlled.

Printed Copies are Uncontrolled.
Title: MANAGEMENT OF CHANGE PROCEDURE- WYANDOTTE

1. PURPOSE
The Management of Change (MOC) system is intended to ensure that the safety, health,
and environmental impact of all modifications to processes, equipment, chemicals, 3.1.to
the implementation of the change.
2. SCOPE
This procedure applies to all changes as defined in Section 3.0 undertaken at the
Wyandotte Site.
3. DEFINITIONS
3.1. Change – A change in the technology of manufacturing, chemicals, and process

equipment, or a change in the procedures of operating the process and related
equipment, or in the organization of the department that can affect safety, the
environment, quality, or efficiency. This definition applies to manufacturing and
pilot plant operations, as well as application and research laboratories. Examples
of changes are:
3.1.1 Chemical/Technology changes – include modification of operating

conditions to outside of predefined safe operating limits, alarm or interlock set
point revisions, PLC software revisions, interlock logic revisions, introduction of
new chemicals, chemical substitution, and chemical re-introduction.
3.1.2 Equipment changes – include new piping/equipment, piping

rearrangements, and equipment revisions, new materials of construction, or
design parameters, impairment of fire water systems, impairment of alarm
systems.
3.1.3 Procedural changes – include standard operating procedures, emergency

procedures, safe work procedures, temporary operating procedures,
maintenance/inspection procedures, temporary operating procedures,
maintenance/inspection procedures or development of a new procedure for new
equipment installations.
Note that for changes that are procedural clarifications, formatting and/or
procedure grammar corrections ONLY, each unit can optionally use a document
control method of their choice to review and track these changes. Further, at the
discretion of the Unit Production Manager, for Mandatory Use Operating
Procedures, where personnel must use a procedure and initial each step upon
completion, a document control method of the unit’s choice may be used when
changes do not involve adding new steps that an operator nor any other
employee expected to use the procedure would need training on (essentially, the
operator/employee has already been trained and is competent in all aspects of
the procedure requirements). Changes to these procedures are still subject to a


hazard review, should be approved by management, and should comply with

regulatory requirements.
3.1.4 Personnel/Organizational changes – include a change in the number of

people, structure of an organization, development of a new role in an
organization, instrument/electrical or maintenance support, or contractor
for the site or unit, and absence from job for extended period.
Organizational changes should also include a transition plan where
appropriate.
3.1.5 Temporary change – planned for a limited duration; such as, a trial or
evaluation or by-pass of a safety system for maintenance. Planned
operation of a process outside its normal operating range or transfer of a
product from its normal process train to another.
3.1.6 Emergency change – immediate actions used to avoid; or control a

spontaneous emergency situation.
3.1.7 Facility change – includes buildings, utilities, containers,

process/emergency equipment location and other non-production related
areas.
3.1.8 Replacement-in-kind – an item, equipment, chemical, procedure etc. that

meets the design specification of the item it is replacing. Management of
Change is not required. Examples are:
 Equipment (vessels, agitators, heat exchangers, etc.) fabricated

exactly to the original design and specification or existing approved
design and located in the same position as the original.
 Equipment and materials that are manufactured by an approved

supplier to a standard specification, such as bolts, gaskets, flanges,
steam traps, piping, insulation, structural steel.
 Instrumentation (transmitters, pressure and temperature gages, etc.) of

the same specification and range, and purchased from an approved
supplier. A change in instrument type e.g. RTD to thermo-couple does
not constitute a replacement in kind.
 Electric motors, fuses and circuit breakers of the same specification

from an approved supplier.
 Replacement of piping with the same size, material, flange make-up

and routing as the existing.

3.1.9 Batch Plant Operations change – re-configuring a process to produce a

different product does not require an MOC provided that:
 The different product has previously been produced in the recent past
and the process for that product has undergone an EHS review such
as a PHA or PSSR and maintains the basis of safety for that process.
 The re-configuration does not introduce new raw materials.
 The Standard Operation Procedure and training is in place for how to
manufacture the different product.
 A Standard Operating Procedure is in place, including appropriate
documentation requirements, to outline the steps necessary to
rearrange the equipment to produce the different product.
3.1.10 Procurement Initiated Changes - Covered changes that will affect specific
units or will have site wide implications must follow Change Management
procedures. This includes changes in suppliers, raw materials
(specifications, concentrations, etc.), equipment specification changes
(materials of construction, pump seal type changes, pressure/electrical
ratings differences, etc.), modes of delivery, etc. The Procurement
Department is responsible for communicating the change with the affected
unit(s) prior to the change being implemented. Where appropriate, the
affected unit(s) is responsible for entering a MOC into change manager.
3.2 Change Administrator - Person responsible to close out the change and ensure
changes meet requirements. The individual assigned to a particular change,
responsible for coordinating all aspects of the change. The Change Coordinator
ensures that each component of the MOC and PSSR is adequately addressed,
maintains appropriate documentation, obtains necessary approvals and training
sign-offs prior to the change, and tracks all related action items to completion. The
Change Coordinator is also responsible for ensuring that the startup date and time
are accurate and that affected employees are notified upon actual startup (and
termination if temporary) of the change. Change Coordinators must be
knowledgeable in the requirements of this procedure, WYN032.075.
Normally, an engineer, can be EHS or other.

 Identified in the Unit Setup
 Should be the person that oversees the MOC program.
 This person can see the “Close” out button in Tab 9
3.3 Change Coordinator - Person who is assigned to manage the change.


 The program will initially add the person who initiates the change as
Change Coordinator
 Can be changed on TAB 1 or TAB 2 in pop up box when the Unit
Approver approves.
3.4 Change initiator/Requestor - Person who fills out Tab 1 and submits the change
request. Normally, a person already assigned a task by unit manager.
3.5 Change Unit Approver - Person the change request is sent to for approval to
proceed with the change request. Normally Unit Manager.
3.6 Formal Safety Review – The process of conducting a formal Step Review for the
purposes of identifying a proposed change is safe to operate according to BASF
procedures and processes.
3.7 Informal Safety Review – An informal safety review may constitute any of the
following processes: a Step Review not mandated by BASF Corporate
requirements based on project dollar value, a key word checklist review, a PHA or
other unit procedure used to ensure a proposed change can be safely
implemented.
3.8 Pre-Start Up Safety Review (PSSR) – Formal process for reviewing the
readiness to operate safely for an installed change.
3.9 PSM – Process Safety management – Standard defines requirements for highly
hazardous chemicals for preventing or minimizing the consequences of
catastrophic releases of toxic, reactive, flammable, or explosive chemicals.
OSHA’s 29 CFR 1910.119 was developed to minimize the effects of process
incidents on employees.


4. PROCEDURE
4.1. The Lotus Notes Change Manager database shall be used to review and
document all changes and PSSRs defined under 3.1 (See Exceptions under 5.3).
4.2. The approval process for changes must be followed and documented using the
Change Manager DB.
4.3. Exceptions:
4.3.1. Emergency type changes can be verbally authorized (approved) by

supervision and then, documented, reviewed and formally approved after
the situation has stabilized. An “Emergency Change” form is available and
can be printed out from the Change Manager DB by accessing the
database and clicking on “?” Help In the menu bar.
4.3.2. Replacement-in-Kind
4.3.3. A minor change is made to a Standard or Procedure that does not affect
the contents (i.e. updates to phone numbers).
4.3.4. A Batch Operation as meets the provisions outlined in 3.1.9
4.3.5. Temporary Fire System Impairment, lasting less than 24-hours, can be
documented and communicated by contacting the Site Utilities Group prior
to the impairment.
4.4 Wyandotte CARES Management of Change Procedure

The Wyandotte CARES group has established a process to determine whether or
not a potential change needs to be entered into Change Manager. If an MOC is
required the necessary supplemental PSSR checklists appear on subsequent
tables. If an MOC is applicable then the Change Requestor will enter an MOC
into the Change Manager (CM) system and submit to the unit approver. At this
point the Wyandotte MOC process will be followed.
4.5 MOC ORIGINATION: INITIATING A CHANGE

Any person can initiate or recommend that a change be made. Minimal
information, specifically, a description of the proposed change, the technical basis
of the proposed change, expected impact on the safety and health of the
employees affected by the proposed change, and the duration of the change
should be provided. Any change will require completion of Tab 1, the “Definition”
section of the Management of Change Form.


4.5.1 MOC INITIATION, APPROVAL TO PROCEED AND RISK ASSESSMENT

(TABS 1, 2, &3)
4.5.2 The MOC Initiator and the Change Coordinator are responsible for
implementing the entire MOC procedure. The Initiator or Change
Coordinator evaluates the proposed change and identifies information that
must be collected for the particular change.
4.5.3 Initiator assigns the Change Coordinator (can be the MOC Initiator) and
describes the change; the justification for the change, if temporary sets the
expiration date and submits the MOC to the Approver (Tab 1).
4.5.4 The Approver determines the level of review required for the MOC and if
necessary assigns the appropriate personnel to conduct and participate in
the review (Tab 2).
4.5.5 The EHS reviewers are assigned at this point. All MOC’s should have the
Individual Approvers radio button marked “YES”. This will automatically
populate the EHS reviewers in the reviewers table.
4.5.6 To help determine if an air permit is needed or an existing permit must be

amended because of a change in the unit an Environmental Change
Checklist has been developed (See Attachment A). The completed form
should be attached to the MOC.
4.5.7 To assist with the evaluation for addition and use of new chemical a New
Chemical Environmental Review Instructions and Environmental Review
Form have been developed (See Attachment B). The completed review
forms should be attached to the MOC.
4.6 Initial Review Capital and Non-Capital Projects

A Management of Change (MOC) is required to be completed for all capital
projects. For non-capital projects, it should also be determined in the initial review,
based on the impact of the change, whether additional technical or specialized
reviews (HAZOP, Environmental, Occupational Safety and Industrial Hygiene,
Legal, Customer Notification, etc.) are necessary to evaluate the feasibility of the
proposed change.
4.6.1 The following information should be evaluated during the Initial Review:
4.6.2 Technical feasibility of the proposed change
4.6.3 Justification and necessity of the change


4.6.4 Adequate design information/specifications to perform a valid review

(based on group judgment and knowledge of the process).
4.6.5 Whether modifications to written procedures are required (including time
limit for temporary changes).
4.6.7 The expected duration of the change for temporary changes.
4.6.8 Review of relevant Process Hazard Analysis (PHA) to verify proposed
change does not violate existing safeguards or create a potential hazard.
4.6.9 A risk level assessment is used to determine the potential impact of the
change on safety and health. A risk assessment is used for all MOC’s
including capital projects. This is done in the Change Manger DB, Tab 3
Risk, where the appropriate assessment method can be selected.
4.6.10 Documentation of the Initial Review should be maintained with the MOC. If
a formal meeting is held, minutes from this meeting can document the
topics discussed, the decisions reached and the names of the reviewers
(Tab 2).
4.6.11 The Approver then either “Approves” to proceed with the change, “Denies”
the change, or puts the change on “Hold” due to a concern. If the
Approver has a concern the “Concern Page” is completed detailing the
concern and responsible person is assigned. If the concern is satisfied the
Approver approves to proceed. At this time the Approver can change the
MOC Coordinator if necessary (Tab 2).
4.7 Risk Level Determination Tab 3 – Risk Assessment - Risk Method: Either
Mode of Failure or PHA/Step Review/Other is now required on Tab 3 (risk level
assessment must also be selected). On tab 3, we must complete the risk level
assessment and mode of failure if no other safety review is performed (e.g., Step
Review, R&D Safety Review, etc.)
 As required per PSM/RMP regulations and BASF Responsible Care

Requirements, MOCs must contain a review of the impact to safety and
health.
 The risk level assessment is only an assessment of the level of risk, and is
not the safety review. A safety review must document the impact to safety
and health and needed safeguards.


Risk Level Assessment

Risk Level Assessment - Is a list of questions that will determine the minimum safety reviews
needed for this change.
After all questions are answered, the “View Risk Matrix” button above the section will
show the required level of safety reviews.
Informal Review – A hazard review that may be done with two or more individuals and involves
a review of the hazards and documentation of them via the mode of failure method or by adding
them to the PHA at a minimum
Formal Initial Hazard Review – A hazard review that follows the same guidelines as a Process
Hazard Analysis (PHA) or BASF capital project review. All capital projects should have a
formal hazard review regardless of the Risk Level as per BASF Corporate procedure.
If this is a capital project, then the step review process may be followed in


lieu of doing the mode of failure method/formal PHA. However, any supporting
hazard/safety review documentation should be attached in Tab 3, including the meeting
minutes for capital projects and open action items should be documented in Tab 4.
Mode of Failure
 What-If type safety review
 Describe the potential mode of failure
 Describe the hazard to personnel
 Determine if control measures are existing or needed.
 If needed, create an action item in Tab 4.
Under Mode of Failure a risk level of assessment must be assigned. See guidance below:
Upon completion of the Risk Assessment Tab a Pre-Start Up Safety Review (PSSR) must be
competed as follows:
 Tab 3 risk levels 1 & 2 = PSSR Short Form

 Tab 3 risk levels 3 & 4 = PSSR Long Form
Complete tab 4 of the MOC (PSSR Checklist & Action Items).

If you answered yes to any of the questions under the Items to Complete Prior to Startup
section:

 For each yes answer, complete the required categories.

 Identify your change under the Short Form Change Type, and complete the
required categories.
Tab 3 – Risk Assessment - Also due to the same PSM/RMP requirements, the box at the bottom,
“Reviewers for Impact on Safety and Health” is now a required field.
The field is now red with a double (**) asterisk, indicating it is a required field
This change was the result of Internal PSM/RMP/RC compliance audit findings which have been
written in regards to the impacts to safety and health not being addressed prior to a change.
Therefore, these updates to change manager will promote compliance.
Administrative Changes
For Administrative Changes or When there are no anticipated Failure Modes (Negative
Declaration)
4.8 MOC CHECKLIST (TAB 4)
4.8.1 All questions in the Pre-Startup and Post Startup sections will be answered
YES or NO. Addition Action Items can be added.
4.8.2 YES answers will be assigned as an Action Item. Final Approval for
startup cannot be submitted until the Pre-Startup Action Items are
complete. All Pre-Startup Action Items shall be completed prior to startup
of the change.

4.9 MOC TRAINING (TAB 5)
4.9.1 Training documentation is automatically maintained in the Lotus Notes

Change Manager system when the electronic signoff feature of the Change
Manager system is used.
4.9.2 In the event that another means of training is used, evidence that those
affected by the change have been informed/trained MUST be maintained.
A sign-up sheet may be used and attached on the MOC Training Page.
4.9.3 NOTE: All signatures do NOT have to be signed off in order to start up.
Sign-off prior to startup may not be possible due to shift schedules.
Employees are required to be informed/trained and signed off before
operating or working on equipment or processes that have been changed.
Within the Lotus Notes MOC Database

Tab 5 - Training - Language has been reworded as requested by several sites and operations
personnel. It now allows them to acknowledge that they were either informed OR trained on the
change.
Reminder: Sites must makes sure they train and/or inform as appropriate depending on the
change and the impact it has to an individual’s job task.
4.10 PSSR PRE-STARTUP SAFETY REVIEW (TAB 6)

The PSSR team should review the status of any action items/open issues from the
MOC, Step 3, PHA, or EHS reviews with the team. In addition, the status of PSSR
action items should be reviewed.
4.3.6. A PSSR must be completed or waived before approval is given to startup a

change.
4.3.7. PSSR procedure and the Long Form Pre-Startup Project Safety Review
Checklists can be found in Appendix D of this procedure.
4.11 MOC APPROVAL TO STARTUP (TAB 7)

Approval to startup must be obtained from the Unit/Department approver before
the change can be implemented. In addition, the Final Approver can require
additional approvers as necessary.
4.11.1 Determine the start-up approvers required for the change and send a
request for approval to the personnel specified.


4.11.2 All Pre-Startup Action Items must be completed before the request for
start-up approval can be submitted.
4.12 MOC TEMPORARY CHANGE (TAB 8)

Temporary changes must follow the full management of change procedure. If a
change is "Temporary", the duration of the change shall not exceed 90 days
without additional review. Temporary change must follow one of the following
three completion options:
4.12.1 “Change Removed” – all affected personnel notified by email or other

appropriate means.
4.12.2 “Extend expiration date” - all affected personnel notified by email, or other
appropriate means, of the new expiration date.
4.12.3 “Make Permanent” - A new Change will be created & certain information
copied into the new document.
4.13 MOC CLOSE-OUT

After approval is obtained to startup the change, the Change Coordinator or other
designated person will sign off the change as complete.
4.14 TRAINING
Is required:
4.14.1 Initially when employee is assigned responsibilities for recognizing
changes, including a General MOC awareness in Success Factors.
4.14.2 Both site and unit specific training is required to ensure all
employee understand the MOC process within their respective
groups.
4.14.3 Whenever changes are made to the standard,
4.14.4 Whenever deviations to the requirements are identified.
4.14.5 Additional training materials are available in Change Manager by
selecting the on “?” “Help” button and choosing links titled “Link to
Training Materials on Change Manager” and “Frequently Asked
Questions”. The online help section for Change Manager is a good
resource for questions concerning the Lotus Notes Change
Manager database.
Note: Additional training material is also available through the Wyandotte
EHS group that will utilize site training material in addition to what is
provided in the Change Manager Help section.
4.14.6 Training should incorporate both the requirements of this procedure
as well as any unit specific requirements above and beyond those
listed in this standard.


4.14.7 Operating/Lab Units are responsible for ensuring training of

personnel is completed as required.
5. RESPONSIBILITIES
5.1. All employees have the responsibility to:

5.1.1. Recognize a change before initiating
5.1.2. Initiate the MOC, per this policy
5.1.3. Assist in making changes
5.1.4. Participate in training
5.1.5. Provide input in maintaining a safe working environment
5.2. Change Requestor/ Initiator- has the responsibility to:

5.2.1. Initiate the MOC and PSSR by defining the change and reason for the
change
5.2.2. Assigns Change Coordinator and PSSR Coordinator (can be the
requestor)
5.2.3. Forwards to the appropriate person (Operations Manager, Site Manager or
designee) for approval to proceed
5.2.4. Documents the technical basis on Tab 1 and as necessary participates in
Technical Review if required
5.2.5. May assist with the completion of the hazards analyses or risk assessment
5.2.6. As appropriate may participate in PSSR
5.2.7. May assist Change Coordinator with the completion of the pre and post
start-up safety review checklists’ items and assigns action items
5.3. Operations/ Service Manager/Change Unit Approver - has the overall

responsibility to:
5.3.1. Approves the initial request of the change, helps identify is customer
notification is required and specifies if and what technical approval is
necessary.
5.3.2. Solicit employees participation by getting their input on changes
5.3.3. Determines if Technical Review is required and assigns Technical
Reviewers.
5.3.4. Ensure all items on the MOC and PSSR checklists have been completed
as required, prior to implementation of the change
5.3.5. Give final approval to implement the change
5.3.6. Ensure affected personnel are trained in the MOC requirements and
changes


5.4. MOC Coordinator - has the responsibility to:

5.4.1. The individual with overall responsibility for coordinating all aspects of the
change, implementing the change and ensuring compliance is met with
WYN032.075 when making changes.
5.4.2. Receives appropriate approvals on Tabs 2 and 7 prior to the change and
assigns and tracks all related action items to completion.
5.4.3. Fills out the Risk Assessment (with other personnel as necessary) and
assembles the required team for the appropriate Hazard Review according
to the Risk Level.
5.4.4. Ensure the appropriate personnel (including the Production Engineer for
the area) are on the distribution list for the MOC in Tab 2.
5.4.5. Ensures EHS review and approval personnel are identified in tab 2.
5.4.6. Where appropriate consults with the Learning and Developmental (LDC)
Coordinator about the change so that the LDC knows how to understand
their role in the training process. As needed an action item in Tab 4 for the
LDC to work on any training that may be identified as an action item.
5.4.7 Responsible for organizing the Pre-Start up Safety Review (PSSR) prior to
startup and documenting the PSSR on Tab 6 as identified during the
Hazard review.
5.4.8 Ensures that the startup date and time are accurate on Tab 6 (may need to
adjust to reflect accurate time following final approval) and that affected
employees are notified upon the actual start up (and termination if a
temporary change). This should also be checked before submitting the
MOC to the final approver.
5.4.9 Tracks temporary changes to ensure the expiration dates are met or the
MOC is altered as appropriate.
5.4.10 For groups that do not have an LDC, the Change Coordinator is
responsible for filling out the Training Tab (Tab 5) of the Change Manager
MOC and should follow the same requirements as an LDC outlined in this
procedure.
5.5. MOC Administrator - has the responsibility to:

5.5.1. Manage the Operating, Applications and or Research Unit’s overall MOC
program
5.5.2. Establish KPI’s to ensure MOC’s are being initiated, completed and closed
in a timely manner.
5.5.3 Works with the MOC Coordinator to make sure the MOC is closed out in a
timely manner.
5.6. Technical Reviewers – have the responsibility to:

5.6.1. Review change request and sign (if signature is required) the form
acknowledging the review is completed and the change accepted.


5.7 EHS Approver- have responsibility to:

5.7.1 Reviews the change request in Tab 1 and determines if any significant
EHS issues are identified prior to approval.
5.7.2 Based on the review approves the change allowing it to move forward.
5.8 Maintenance Department/EHS Department/Other

Has responsibility for recognizing changes that are covered under WYN032.075
and for initiating and completing MOCs for all changes initiated by their
department.
5.9 Procurement Department

Has the responsibility of communicating any change they initiate with the affected
unit(s) to allow them to fully evaluate the change in accordance with this
procedure prior to this change being implemented.
5.10 Shift Supervisor

5.10.1 Typically fills out Tab 1 when an emergency change occurs (must be filled
out within 24 hours after the change) and assigns a Change Coordinator.
5.10.2 May be asked to play a role in the training process to help ensure all shifts
are trained prior to returning to work on the affected equipment/in affected areas.
5.11 Hazard Review Team

5.11.1 Team formed based on the Risk Level Assessment results to document
the hazards of the change, perform risk ranking using Corporate Risk Matrix and
confirms/determines the needed control measures.
5.11.2 May use the Keyword Checklist (used during Capital Project Reviews) to
help identify hazards.
5.11.3 As required by Table 1, the team should follow the informal or formal
review type depending on the outcome of the Risk Assessment and the corporate
results.
5.11.4 Verifies that the proposed change does not violate existing safeguards in
the relevant PHA nor creates a potential hazard scenario.
5.11.5. Reviews technical feasibility and justification for the change (and updates
on Tab 1 as necessary); determines and adds any additional technical reviewers to
Tab 2.
5.11.6 If controls are needed, assigns action items it Tab 4.
5.11.7 Determines whether Process Safety Information needs updating and
whether modifications of written procedures are needed.
5.11.8 Determines PSSR team (may be same individuals as Hazard Review
Team) and those required for walk through (if changes results in observable or
tangible changes).
5.11.9 Begins assigning action items on Tab 4 (checklist and action items) and
may assist the Change Coordinator with implementation phase of the MOC.


5.12 Learning and Development Coordinator (LDC)

5.12.1 The LDC is responsible for completing/overseeing the completion of the
training tab within change manager for all production driven MOCs (and
maintenance driven for the maintenance LDC).
5.12.2 The LDC is responsible for coordinating the appropriate
training/communication to the personnel whose job task will be affected by the
change (including maintenance, contractors, and those employees involved in
operating the process) and assuring that this is completed prior to the change or
prior to the employee returning to work on the area/equipment affected by the
change.
5.12.3 It is the LDC’s responsibility to determine when the appropriate time is to
do the Communication/training. Notifying and communicating the change too early
may present a hazard in itself.
5.12.4 The LDC is responsible for determining whether communication is
acceptable or if training is necessary and in what capacity depending on the type of
change, the risk, and regulatory requirements. Note that training may include a
type of competency test (demonstration, observation, written test, oral test,
computer based test, and/or other).
5.12.5 The LDC is responsible for documenting and coordination a plan of action
to ensure that the necessary employees who are not present at work are
trained/informed prior to returning to work in the affected area/on the affected
equipment.
5.12.6 Helps the Change Coordinator in assuring that all employees are made
aware of the actual startup time of the change (verbally/or electronically). Utilizing
the shift supervisor is often key in achieving this task.
5.12.7 Responsible for training all new employees within the production units on
WYN032.075 (or the maintenance department for the Maintenance LDC) that are
expected to have a role in Change Manager as identified in WYN032.075.
5.13 Pre-start up Safety Review (PSSR) Team

5.13.1 Ensures that construction and equipment is in accordance with design
specifications (meets what design team intended)
5.13.2 Ensures that safety, operating, maintenance, and emergency procedures
are in place and accurate
5.13.3 Ensures that for new facilities/stationary sources (see definition in
procedure), a process hazard analysis (which meets PSM/RMP regulatory
expectations for regulated facilities) has been performed and recommendations
have been resolved or implemented before startup; and modified stationary
sources meet the requirements contained in management of change;
5.14.4 Ensures that training of each employee involved in operating a process
has been completed and documented in Tab 5 (and ensures documentation is
made for those employees that are not present at work and that a plan is
discussed for their training)


5.14.5 Verifies that all items marked as “before startup” items in Tab 4 has been
completed and reviews the status of any action items/open issues from the MOC,
any final punch list items, Step 2/3 meeting minutes, PHA, or hazard review to
ensure that everything that must be done prior to startup is complete (plus they
ensure that these items are identified in the MOC or exist in an attachment to it)
5.14.6 Verifies that the technical basis on Tab 1 adequately describes the
reason for the change.
5.14.7 Verifies that the modifications to operating procedures and P&ID redlines
have been completed
5.14.8 Performs a walk through for all changes that result in physical
modifications to the unit and documents any deficiencies or open items. These
items should be documented and tracked to completion in the MOC. Document or
attach proof of the walk-through.
5.14.9 Attaches completed PSSR long forms when required or any unit specific
PSSR forms to Tab 6.
5.14.10 Ensures the team members are listed in Tab 6 or are on an attachment in
Tab 6.
5.14.11 Assists the Change Coordinator in completing Tab 6 and the startup time
and date.
5.14.12 Note that if the change goes through the capital project review steps,
Step 4 must be attached to the PSSR Tab in Change Manager to serve as
documentation of the PSSR and BC032.013 should be followed for Capital Project
Reviews, including Step 4 procedures. Items left over from Capital Project
Reviews should be entered as Action Items on Tab 4.
5.15 Unit Final Approver (Tab 7 approver)

5.15.1 Can’t be the same individual as the Change Coordinator
5.15.2 Provides final approval before startup after ensuring that compliance has
been met with WYN032.075, (checks Tabs 1-6 to ensure completeness and
compliance with WYN032.075)
5.15.3 Verify that a walk-through was done and documented for all changes
resulting in observable changes
5.15.4 Verifies that the startup date and time listed in Tab 6 and 7 is after the
present date on which they plan to provide Final Approval. If it isn’t, consult with
Change Coordinator prior to providing Final Approval.
5.15.5 Verifies that LDC has fulfilled their role in the training piece of the MOC
and has already provided their Final Approval on Tab 7.
5.15.6 Verifies that the PSSR was done correctly, documented properly, and that
all before startup items are complete.
5.15.7 (For production units) Checks that the OSIH team member was a
reviewer on Tab 2 and provided his/her approval.


5.16 EHS Approver (OSIH Team Member)

5.16.1 Responsible for ensuring that the hazard review is done in accordance
with WYN032.074, that the impacts of the change have been addressed and
documented properly in Tab 3
5.16.2 Responsible for providing approval for the change to move forward on
Tab 2 after ensuring that the hazard review was done and documented properly
5.16.3 A required participant in the hazard review when at least a Level 2 or D
risk
5.16.4 Responsible for ensuring that the box for reviewers for impacts to safety
and health is filled in on the bottom of Tab 3
5.16.5 If Environmental impacts are identified, the OSIH team member is
responsible for adding the Environmental team member as an additional approver
on Tab 2
5.16.6 Responsible for participating in the PSSR when EHS expertise is needed
5.16.7 Periodically check to ensure action items are being done on time and that
MOCs are being closed out in a timely manner


6 RELATED DOCUMENTS
Description of Procedure/Document Corporate No. Wyandotte No.

Environmental Change Notification Checklist WYN032.075A
Environmental Change Review Checklist WYN032.075B
MOC Screening Checklist OSIH WYN032.075C
Pre Start Up Safety Review (PSSR) From Table WYN032.075D
Wyandotte MOC Process Flow WYN032.075E
Management of Change (MOC) in the Operational
Phase of Facilities – Global Process Safety
Ecology & Safety Project Reviews BC032.013

Title: MANAGEMENT OF CHANGE PROCEDURE -
WYANDOTTE


Preparer: Owner: Approver:
EHS Team Member EHS Team Leader OHMICAN Hub Manager
Tom Ozimek Tom Ozimek Peter Dulik


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What is the purpose of the Management of Change procedure?

What is the purpose of the Management of Change procedure?

What types of changes does this procedure apply to?

What types of changes does this procedure apply to?

Title: MANAGEMENT OF CHANGE PROCEDURE -

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

The Electronic Document is Controlled.

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

3.1. Change – A change in the technology of manufacturing, chemicals, and process

3.1.1 Chemical/Technology changes – include modification of operating

3.1.2 Equipment changes – include new piping/equipment, piping

3.1.3 Procedural changes – include standard operating procedures, emergency

The Electronic Document is Controlled.

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

hazard review, should be approved by management, and should comply with

3.1.4 Personnel/Organizational changes – include a change in the number of

3.1.6 Emergency change – immediate actions used to avoid; or control a

3.1.7 Facility change – includes buildings, utilities, containers,

3.1.8 Replacement-in-kind – an item, equipment, chemical, procedure etc. that

 Equipment (vessels, agitators, heat exchangers, etc.) fabricated

 Equipment and materials that are manufactured by an approved

 Instrumentation (transmitters, pressure and temperature gages, etc.) of

 Electric motors, fuses and circuit breakers of the same specification

 Replacement of piping with the same size, material, flange make-up

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

3.1.9 Batch Plant Operations change – re-configuring a process to produce a

Normally, an engineer, can be EHS or other.

3.3 Change Coordinator - Person who is assigned to manage the change.

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

The Electronic Document is Controlled.

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

4.3.1. Emergency type changes can be verbally authorized (approved) by

4.3.4. A Batch Operation as meets the provisions outlined in 3.1.9

4.4 Wyandotte CARES Management of Change Procedure

4.5 MOC ORIGINATION: INITIATING A CHANGE

The Electronic Document is Controlled.

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

4.5.1 MOC INITIATION, APPROVAL TO PROCEED AND RISK ASSESSMENT

4.5.6 To help determine if an air permit is needed or an existing permit must be

4.6 Initial Review Capital and Non-Capital Projects

The Electronic Document is Controlled.

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

4.6.4 Adequate design information/specifications to perform a valid review

 As required per PSM/RMP regulations and BASF Responsible Care

The Electronic Document is Controlled.

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11

Risk Level Assessment

The Electronic Document is Controlled.

Site Function: Ecology, Health & Safety

Wyandotte Reviewed: 7/15 Effective: 6/3/16 Supersedes: 12/11