Management Of Change Procedure (Dupont’s)

DuPont’s Safety Standards into the Management of Change (MOC) Procedure ensures that the highest
level of process safety and risk management is applied, following DuPont’s Safety Principles. DuPont, a
global leader in industrial safety, emphasizes proactive hazard identification, worker protection, and risk
mitigation across all processes. Their safety framework includes engineering controls, employee
engagement, and rigorous safety protocols. Let’s integrate DuPont’s safety practices into a detailed step-
by-step MOC procedure for a chemical manufacturing industry.

Management of Change (MOC) Procedure with DuPont Safety Standards

DuPont’s Core Safety Principles Applied:

1. Safety Leadership: Demonstrate visible leadership commitment.

Objective:

To ensure that all changes in processes, equipment, materials, and personnel are evaluated and
managed to uphold DuPont’s safety standards and minimize risks to workers, the environment, and
assets.

Scope:

This MOC procedure applies to all types of changes within the chemical manufacturing plant, including
changes to processes, equipment, control systems, raw materials, and personnel.

Step-by-Step MOC Procedure with DuPont Safety Standards

Step 1: Initiation of Change Request

Identify Need for Change: Any proposed change to the process, equipment, or materials must be flagged
by the operations or engineering teams.

MOC Form: The initiator submits an MOC request form detailing:

Type of change (process, equipment, personnel, etc.).

Reason for the change (e.g., efficiency improvement, cost reduction).

Potential risks identified (following DuPont’s proactive risk identification approach).

Employee involvement in the change request process.

Example: The engineering department submits an MOC request to change a reactor’s operating pressure
limits to increase efficiency.
Step 2: Preliminary Review with Safety Leadership

Safety Review by Leadership: The PSM (Process Safety Manager) conducts a preliminary review of the
change to ensure it aligns with DuPont’s safety protocols.

Risk Categorization: Changes are categorized as low-risk, medium-risk, or high-risk based on potential
safety impacts. DuPont’s risk matrix is applied here to systematically assess the risk level.

Example: The change in reactor pressure is flagged as medium-risk due to potential process safety
implications.

Step 3: Employee Involvement and Safety Communication

Engage Employees: Following DuPont’s principle of employee involvement, relevant personnel

Communication: Conduct toolbox talks, safety meetings, and share the change details with all affected
teams.

Example: A team meeting is held to discuss the new operating conditions and potential safety concerns
with operators and maintenance staff.

Step 4: Comprehensive Risk Assessment (HAZOP)

Form a Cross-Disciplinary Team: Assemble a HAZOP (Hazard and Operability) study team, including
process engineers, safety officers, operations, and maintenance, to evaluate the risks.

DuPont’s Risk Hierarchy:

Elimination/Substitution: Can the change be done in a way that removes the hazard?

Engineering Controls: What controls can be implemented to contain the risks?

Administrative Controls and PPE: Define operational controls and PPE requirements as the last line of
defense.

Example: The team identifies that increasing reactor pressure requires reinforcing the safety relief system
and adding additional pressure monitoring alarms.

Step 5: Approval of Changes

Approvals from Leadership: Based on the risk assessment, the change is reviewed by senior
management and safety leadership.

Safety Controls and Mitigation Measures: Before approval, all necessary safety controls must be
implemented, adhering to DuPont’s stringent engineering controls standard.
Example: The proposed pressure increase is approved after ensuring the installation of automated
shutdown interlocks and additional pressure relief valves.

Step 6: Update Documentation and Safety Procedures

Revise Safety Documents: Update process documentation (P&IDs, process flow diagrams), Standard
Operating Procedures (SOPs), and emergency response plans

Employee Training: Conduct thorough training on updated operating conditions and new safety
measures, ensuring compliance with DuPont’s operational discipline standards.

Example: Operators are trained on monitoring reactor pressure and the new safety systems in place to
prevent overpressure events.

Step 7: Implementation and Monitoring of Change

Controlled Implementation: Implement the change in a controlled, step-by-step manner. Monitor the
system for any deviations or unexpected issues.

Safety Oversight: Ensure safety leadership is involved in observing the implementation phase, as per
DuPont’s visible leadership principle.

Example: The change is implemented during a scheduled shutdown, and a team of engineers and safety
officers closely monitor the reactor during the first operational run under new pressure limits.

Step 8: Post-Implementation Review and Continuous Improvement

Post-Implementation Safety Review: Conduct a review after the change is implemented to ensure it
operates as expected and that no new risks have arisen.

Apply DuPont’s Continuous Improvement: Evaluate the change and its impact on safety performance.
Incorporate lessons learned into future procedures and training programs.

Example: The PSM team performs a thorough review of the process after 30 days, confirming that the
pressure increase has improved efficiency without introducing new hazards.

Step 9: Final Approval and MOC Close-Out

Final Sign-Off: After the post-implementation review, senior management and safety officers provide the
final sign-off.

Archive Records: All MOC documentation, including risk assessments, approvals, and training records,
are archived following DuPont’s documentation standards for future reference and regulatory audits.
Example: The MOC process is closed, and the change is officially implemented as part of the standard
operations

Example of an MOC with DuPont Standards: Increasing Reactor Pressure

Change Request: A proposal to increase the operating pressure of a chemical reactor to improve
production efficiency in Reaction process.

1. Initiation: An engineer submits an MOC form requesting an increase in reactor pressure from 10
bar to 12 bar to improve yields.
2. Preliminary Review: The PSM manager categorizes the change as medium-risk due to the
increased chance of overpressure and explosion hazards
3. Employee Involvement: Operators and maintenance teams are involved in discussing potential
safety concerns during a toolbox meeting
4. Risk Assessment (HAZOP): The team identifies risks of pressure buildup and designs safety
mitigations, including reinforced pressure relief systems and automated pressure shutdowns.
5. Approval: Senior management approves the change, subject to the installation of additional
engineering controls.
6. Update Documentation: SOPs and P&IDs are updated, and training is conducted on the new
pressure limits and safety systems
7. Implementation: The pressure increase is implemented during a planned maintenance shutdown,
with careful monitoring by engineers and safety officers.
8. Post-Implementation Review: After 30 days, the system is reviewed, and no safety incidents are
reported.
9. Close-Out: The MOC is closed, and all documentation is archived.

DuPont’s Safety Standards in MOC: Key Takeaways

1. Employee Involvement ensures that everyone affected by the change is part of the safety process.
2. Proactive Risk Management helps identify potential hazards before they become critical
3. Leadership Commitment from senior management ensures safety is prioritized in every change.
4. Continuous Improvement and regular reviews help the facility adapt and enhance safety over
time.
5. Operational Discipline ensures that changes are implemented strictly according to procedures,
minimizing human error.

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