Journal of Loss Prevention in the Process Industries 26 (2013) 499e510

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Journal of Loss Prevention in the Process Industries

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MOC scopingdEnsuring that MOC action items are correctly

and completely described
Rainer Hoff*
Gateway Consulting Group, Inc., 8610 Transit Road, Suite 100, East Amherst, NY 14051, USA

a r t i c l e i n f o a b s t r a c t

Article history: Shortly after initiating a Management of Change instance, the owner develops a list of action items that
Received 28 February 2012 need to be accomplished in order to successfully complete the MOC. This activity is termed “scoping the
Received in revised form MOC”. A well-scoped MOC is efficient and lower risk; a poorly-scoped MOC is inefficient and higher risk.
29 June 2012
The quality of MOC scoping depends largely on the methodology used, with different sites using
Accepted 4 July 2012
anything from no scoping at all, guesswork approaches, checklist approaches, to very sophisticated asset-
based scoping.
Keywords:
This paper reviews the various scoping methodologies using examples from actual MOC processes
Management of Change
MOC
currently in use at chemical plants and refineries. The scoping techniques are then evaluated in terms of
Scoping cost and error susceptibility of the resulting MOCs, using quantitative assessment tools. The results of
Optimization this research provide specific guidelines on how to optimize scoping for small, medium and large MOCs.
Checklist Ó 2012 Elsevier Ltd. All rights reserved.

1. Introduction backwards, “demotion”, or skip forward several states, although

In the U.S. Management of Change, “MOC”, is required by
a number of agencies including PHMSA, the EPA, and most
commonly, OSHA. Various authors (American Institute of Chemical
Engineers, 2008; Chosneck, 2010; Keren, West, & Mannan, 2002;
Sanders, 1996, 2005) have contributed to the knowledge of how to
address the safety aspects of MOC.
MOCs triggered by regulations are usually focused on safety or
environmental concerns. But, some attention should be focused on the
efficiency aspects of the MOC business process, and avoiding unwar-
ranted complexity (Sanders, 2005). To this end, Hoff has adopted
a lifecycle approach for characterizing MOC (Hoff, 2007, 2011).
In a lifecycle model, the business process is divided into a number
of states. During each state, certain actions take place. The states
during which actions can occur depend on the lifecycle. For
a permanent, non-emergency MOC, the states are shown in Fig. 1.
When all the action items, belonging to a given state, are
completed, then the MOC is “promoted” to the next state (this
mechanism is also sometimes referred to as the Stage-GateÔ
process (Cooper, 2001)). In theory, the process flow can also move
Abbreviations: EPA, (US) Environmental Protection Agency; HAZOP, hazard and
operability study; MOC, Management of Change; OSHA, (US) Occupational Safety
and Health Administration; PHA, process hazards analysis; PHMSA, (US) Pipeline
and Hazardous Materials Safety Administration; PSM, process safety management;
P&ID, piping and instrumentation diagram.
* Tel.: þ1 716 636 0200; fax: þ1 716 204 3378.
E-mail address: rhoff@gatewaygroup.com.
these are not shown in Fig. 1.
An MOC begins at the Initiation state. The MOC initiator typi-
cally completes a form with descriptive attributes, including the
name of the MOC, where the change is taking place (area, unit, etc.),
expected duration, the technical basis of change, etc.
1.1. Scoping
During the Scoping state, the work of the MOC is “scoped out”.
At the end of Scoping, the MOC should contain a list of action items,
analogous to that shown in Table 1. Some action items, shown in
italics with an asterisk (*) suffix, are inherent in the MOC process, so
those action items are always part of an MOC. All the other actions
are generated by the scoping activity.
The ultimate quality of the MOC is directly related to the quality
of scoping:
1. Are all the action items present?
2. Are all the action items completely described?
This paper analyzes approaches to addressing both of these
questions.
1.2. Checklists
In order to minimize risks, a fully-scoped MOC must have
a correct and complete list of action items: anything less increases

0950-4230/$ e see front matter Ó 2012 Elsevier Ltd. All rights reserved.
http://dx.doi.org/10.1016/j.jlp.2012.07.007
500 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510

Fig. 1. Lifecycle states for permanent, non-emergency MOC.

risk. Gorovitz and MacIntyre (1976) identified two causes of human These different approaches are described in the following
failure: sections.

1. Ignorance: the knowledge to perform a task does not yet exist

2. Ineptitude: the knowledge to perform a task exists, but it is not
applied correctly. 2.1. Explicit scoping

Their interpretation of “ignorance” is strict, inasmuch as the In “explicit” scoping, the initiator1 is provided no information
knowledge doesn’t exist anywhere in the world. Normally, in plant about how to proceed with scoping the MOC. The MOC form simply
MOC applications, the expectation is that the knowledge exists to requests the inclusion of “all action items”, as shown in Table 2.
properly and safely conduct a change, and that the MOC process In order to consider the MOC properly scoped, the initiator must
should guide the user to avoid failures caused by ineptitude. MOC produce exactly the list of items (without asterisks) shown in
processes often use checklists for scoping purposes: Table 1. The biggest risk in this scenario is that action items are
overlooked.
A checklist is a type of informational job aid used to reduce It’s possible to make a rough estimate of the probability that the
failure by compensating for potential limits of human memory MOC will be properly scoped using the explicit approach. But, in
and attention. It helps to ensure consistency and completeness order to develop a realistic estimate, it is necessary to characterize
in carrying out a task (Wikipedia). how the (potentially overlooked) action items relate to the MOC,
and whether there are any mitigating circumstances.
As indicated in Table 3, the relationship between the action
items and the MOCs is characterized as follows:
2. Ensuring that all action items are present Inherent Action Items: These “inhere” or are part of the
process. The MOC process triggers a PHA, a PSSR, an area manager
MOC scoping can be accomplished in several different ways, approval, and so on. So the probability of omitting these action
which can be labeled: items is 0%.
Critical Path Action Items: These action items are always per-
1. Explicit scoping: starting from essentially a blank sheet formed, because the change cannot proceed without them. For
2. Guided scoping: a traditional checklist instance, if the change is to install an instrument, the change
3. Asset-based scoping: a checklist with an intelligent ruleset doesn’t happen unless the instrument is installed. Installation can’t
proceed unless the instrument is procured (either ordered or
retrieved from the warehouse). However, even though these action
items must eventually be performed, it is possible for them to be
Table 1 overlooked during the initial attempt at completing the MOC. This
List of action items for a hypothetical MOC.
does not result in a compliance problem (since the oversight is
Action item Type of Execution state Role eventually discovered); this results in an economic problem in as
action item much as schedules are disrupted when parts are not available (due
Redline P&ID Perform Change Design Owner to them never having been ordered). The probability of missing
Redline instrument Perform Change Design Owner a critical path action item is c%.
loop diagram
Supportive Action Items: These action items support the
Conduct PHA* Perform Impact Analysis Process
Engineer implementation of the change. For instance putting instruments on
Conduct environmental Perform Impact Analysis Environmental a P&ID and an instrument loop diagram make the procurement and
analysis Rep. installation of the instrument easier. However, it is physically
Review MOC Review Approvals Process Engineer
possible to install an instrument without it ever appearing on
Approve MOC* Sign-off Approvals Area Manager
Procure instrument Perform Implementation Purchasing Rep.
a drawing (although that immediately creates Process Safety
Install in facility (usually Perform Implementation Maintenance Information management violation). If a Supportive Action Item is
triggered by a omitted, early in the MOC process, it is normally discovered during
work order) the PHA. The PHA team would send the MOC back to the respon-
Obtain instrument Perform Implementation Owner
sible person with the direction to redline a P&ID and a loop sheet
spec. sheet
Conduct PSSR* Perform PSSR PSM Coordinator (in this example). So, it is unlikely that the P&ID redlining will be
Update instrument Perform Close-out Owner totally omitteddthe more common case is where the redlines are
database overlooked and then must be redone in response to a request from
Update fugitive Perform Close-out Environmental
emission database rep.
Update P&ID (incorporate Perform Close-out Drafting rep.
1
redlines, as-builts) For the purposes of this discussion, it is assumed that the MOC initiator
Update instrument Perform Close-out Drafting rep. conducts the scoping activity, although scoping can be performed by any compe-
loop diagram tent resource. Use of the term “user” is avoided, since that term tends to be used
Gather metrics* Perform Close-out MOC Coordinator more in computerized MOC applications. Although the author is very supportive of
Close-out the change* Sign-off Close-out MOC Coordinator electronic MOC applications, the discussion in this paper is independent of
implementation technology.
 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510 501

Table 2 s ¼ probability of overlooking an individual Supportive Action

Explicit scoping example. Item.
No. Description ns ¼ number of Supportive Action Items.
(Please provide a list of all action items for this MOC)
i ¼ probability of overlooking an individual Informational Action
Item.
1.
2. ni ¼ number of Informational Action Items.
3. Values of ns and ni are determined by the case at hand, such as
represented by Table 3, but estimating the other parameters is
much more difficult, since these are essentially estimates of human
error rates.
the PHA team. Again, the MOC suffers an economic/schedule Various studies have measured human error rates in industrial
penalty, not a compliance penalty. circumstances (Swain & Guttmann, 1983). A common case is to
Informational Action Items: These are action items that record measure the error rate of a person who is following a procedure
information about what takes place during the MOC. This typically with many steps. Error rates of 0.001e0.1 per task appear in the
includes: literature, with a value of 0.01/task commonly used by the LOPA
community (American Institute of Chemical Engineers, 2001). The
 obtaining data for the equipment files comprehensive research of Swain and Guttmann resulted in 0.003/
 updating drawings (incorporating redlines and as-builts) occurrence (Swain & Guttmann, 1983).
 updating document (e.g. procedures) and putting them into Note that procedures guide the person in his/her thinking and
their final form actions. When attempting to create a task list, as is required in
 updating databases explicit MOC scoping, this guidance doesn’t exist, so one would
reasonably expect that error rates are higher. Even if the person is
Information Action Items are the easiest to overlook, since creating a new MOC by using the action item list from a prior MOC,
there’s usually nothingdbeyond experience and disciplinedto the error rate cannot reasonably drop below the guided task range
remind a person that they are needed. Informational action items (0.003e0.01).
are omitted with a frequency of i%. For the purposes of this analysis, the following values are
The probability that an MOC will be properly scoped, i.e. the chosen:
probability of zero unmitigated scoping errors, can be expressed as
follows: s ¼ 0.03/occurrence when the person is not guided by the
process, as in explicit scoping
PE ¼ ð1  sÞns ð1  iÞni (1) i ¼ 0.1/occurrence when the person is not guided by the process
where,
PE ¼ probability that no action item is overlooked from an MOC,
with explicit scoping. 2.2. Guided scoping

In “guided” scoping, the initiator is provided with a list of many

possible action items and must choose which ones are relevant to
Table 3 the change. Often the checklists group similar items to aid the
Probability of omitting action items, when using explicit scoping. initiator.
Action item Relationship Prob. of Prob. of The analysis of guided scoping is similar to the analysis of
to MOC overlooking initially explicit scoping, except that the beneficial effects of the list, Table 4,
this action overlooking need to be accounted for. The beneficial effects of the list only
this action
Redline P&ID Supportive s
Redline instrument Supportive s
loop diagram Table 4
Conduct PHA Inherent Guided scoping example.
Conduct Informational i
environmental Check all documents to update as part of this change
analysis ,Electrical one-line diagram
Review MOC Supportive s , Instrument loop diagram
Approve MOC Inherent , P&ID
Procure instrument Critical path c , PFD
Install in facility Critical path c .
(usually triggered , Other, please specify___________
by a work order) Select all reviewers for this change
Obtain instrument Informational i , Area Maintenance
spec. sheet , Environmental
Conduct PSSR Inherent , I&E
Update instrument Informational i , Process Safety
database .
Update fugitive Informational i , Other, please specify___________
emission database Select all approvers for this change
Update P&ID (incorporate Informational i @ Area Manager
redlines, as-builts) , ES&H Manager
Update instrument Informational i , Maintenance Manager
loop diagram , Operations Superintendent
Gather metrics Inherent .
Close-out the change Inherent , Other, please specify___________
502 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510

accrue if the item is actually on the list. This can be expressed Table 6
mathematically using: Asset-based scoping. Example ruleset.

s ¼ probability that an action item is omitted. Instrumentation changes

a ¼ list benefit factor. If a ¼ 0, then having the item on the list Does this change involve.
provides no benefit. If a ¼ 1, then having the item is on the list , Adding safety critical instrumentation? If yes, then.

provides the maximum benefit.  Redline P&ID

b ¼ probability that the action item is on the checklist.  Redline instrument loop diagram
By adapting Equation (1), the probability that zero action items  Conduct environmental analysis
are overlooked from an MOC, with guided scoping is:  Review MOC
 Procure instrument
 Install in facility
PG ¼ ð1  ½1  absÞ s ð1  ½1  abiÞ
n ni
(2)  Obtain instrument spec. sheet
 Update instrument database
Potential values for the parameters are:
 Update fugitive emission database
 Update P&ID (incorporate redlines, as-builts)
a ¼ 0.7  Update instrument loop diagram
b ¼ 0.95
, Adding, removing or changing safety critical equipment? If yes, then.

 Redline P&ID
 Redline instrument loop diagram
2.3. Asset-based scoping  .

An MOC initiator who is scoping an MOC using the explicit or ,.

guided approaches must think about the physics of the change (i.e.
the change to be made to the facility), but the expression of those
thoughts is entirely in terms of documents, reviewers and
approvers. The initiator must be able to reliably translate the  Piping and valves
change requirements into a set of action items, without much help  Rotating equipment
from the MOC process.  Pressure vessels
Asset-based scoping overcomes those shortcomings by  Heat exchangers
expressing the checklist items in terms of plant assets. Taking some  Reactors
examples from Matthew’s work (Matthews, 2011), and adapting  Relief valves
them to the present discussion yields a checklist as indicated in  Instrumentation and control valves
Table 5. Note that the checklist is phrased entirely in terms of plant  Structures
assetsdwhich even the most inexperienced person  Distributed control systems
understandsdand not in terms of the resulting action items. Once  Etc.
the checklist, Table 5, is completed, each “yes” answer triggers the
creation of one or more action items. The relationship between The checklists, Table 5, for asset-based scoping contain
checked boxes and action items is contained in a “rule set”, such as scenarios, “adding safety critical instrumentation”, rather than
the example in Table 6. Presenting the checklist items, and the action items “redline P&ID”. If an initiator scopes an MOC, and the
resulting action items, as demonstrated in Table 6, can make the scenario is contained in the ruleset, then the probability of over-
MOC form very long. While some companies have implemented looking an action item approaches zero. For those MOCs where the
asset-based scoping using a paper-based system, it is more scenario is not contained in the checklists, the initiator is forced to
common to do this in an electronic MOC system.
In order to make guided scoping more manageable, the checklist
items were organized into a number of categories (documents to Table 7
update, reviewers, approvers). Similarly, asset-based scoping Parameters used in determining accurate scoping probabilities.
checklists also benefit from organization into categories. However
Parameter Definition Typical Value in
the categories used for asset-based scoping are, as expected, asset- value this example
based (Matthews, 2011):
s Probability of overlooking 0.03
a supportive action item,
without any guidance
Table 5 from the MOC process
Asset-based scoping example. ns Number of supportive 1
action items, unmitigated
Instrumentation changes i Probability of overlooking an 0.10
Does this change involve. informational action item
, Adding safety critical instrumentation? ni Number of informational 6
, Adding, removing or changing safety critical equipment? action items
, Electrically powered instruments in electrically classified areas? a List benefit factor. If a ¼ 1, and 0.7
, Changes to or the addition of a control valve? the item is on the list,
,. then it cannot be omitted.
Relief system changes If a ¼ 0, then having the item
Does this change involve. on the list provides no benefit
, Addition of a relief valve? b Probability that the action item 0.95
, Piping on the relief valve inlet or outlet? is on the checklist
, Changing hydrocarbon relief valve vent routing (atmosphere/flare/process)? g Probability that the asset-based 0.95
, Changing hydrocarbon relief valve relief rate to atmosphere? scenario is contained
,. in the checklist
 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510 503

Table 8  Notify: i.e. be notified about something

Probability that an MOC is properly scoped. 5. State (during which the action item is supposed to be
Scoping approach Variable Prob. that MOC performed)
is properly scoped  Change Design
Explicit PE 51.5%  Impact Analysis
Guided PG 80.7%  Approvals
Asset-based PA 97.6%
 Etc.

If all 5 elements are present, then the action item is completely

described and is labeled “fully-formed” in this paper.
resort to explicit scoping (or guided scoping if that is supported by
the MOC procedure).
3.2. Experimental approach
PA ¼ g þ ð1  gÞð1  sÞ ð1  iÞ ns ni
(3)
It’s not difficult to obtain agreement that action items should be
where, completely described. But, what occurs in actual practice? How
g ¼ probability that the asset-based scenario is contained in the consistent are facility MOC processes in properly describing action
checklist. items?
In order to answer this question, the author critically reviewed
2.4. Worked examples the MOC scoping practices of 15 companies. Each MOC procedure/
form was scored and the results tabulated. Some interesting
The parameters, identified in this paper, are summarized in observations follow at the end of this section, which reveal
Table 7. This permits the calculation of the probability that the MOC different companies’ perspectives about MOC.
is properly scoped, as shown in Table 8.
The results are quite sensitive to the assumptions made for the 3.2.1. MOC scoring
value of s. Indeed Fig. 2 shows how the probability of properly scoping Each MOC form was evaluated, and all checklists were carefully
an MOC falls dramatically with increasing values of s, for both the evaluated. Each checklist item was evaluated on 5 criteria:
explicit approach and the guided approach.2 Asset-based scoping
appears much better, and is relatively insensitive to the value for s. 1. Information content (why is this being done?)
2. Actions (to be performed)
3. Ensuring that all action items are fully described 3. Role (of the person performing the action item)
4. Action item type (perform, sign-off, etc.)
3.1. Fully-formed action items 5. State (during which the action item is supposed to be
performed)
An action item has 5 essential elements:
In order to simplify comparisons between the different
1. Information content (why is this being done?) Each scoping companies’ scoping approaches, a visual comparison technique was
item contains some information, as in the following examples: developed using ideograms. The construction of a scoped action
 Does this change involve piping? item ideogramdlet’s just call them “symbols”dis shown in Fig. 3.
 Does this change involve the plant firewater system? So, a scoping question that specifies an action, e.g. “Redline the
 Does this change involve the fail safe position of control P&ID”, has the top triangle shaded. A scoping question that specifies
valves? a role, e.g. “Process Engineer”, has the lower left triangle shaded. A
 Are tank grounding systems adequate for the new service? scoping question that provides additional information or specifies
 What temperature does the process run at? why something is being done, e.g. “does this change involve
2. Actions (to be performed) examples of actions include: piping?” has the lower right triangle shaded.
 Redline the P&ID A “Perform” action item type uses blue shading; a “Review”
 Update the P&ID action item type uses green shading, etc., as shown in Fig. 4.
 Review the MOC A good scoping question has an indication of what action needs
 Approve the MOC to occur based on the answers to that question.
 Modify the grounding system.
3. Role (of the person performing the action item) examples of 1. Information: Does this change involve the plant firewater
roles include: system?
 Process Engineer 2. Action: Review the MOC
 Mechanical Reliability Engineer 3. Role: Area Safety Rep.
 Area Environmental Rep. 4. Action Item Type: Review
 Operator 5. State: Approvals state
 Maintenance Rep.
 Plant Manager A fully-formed scoping question therefore would have all 4
4. Action item type (perform, sign-off, etc.) examples of action regions shaded, in the appropriate color, and it would be allocated
item types include: to a specific state.
 Perform a task A “partially-formed” scoping question contains 4 or fewer
 Review an MOC or document elements, and therefore its symbol is either partially shaded or not
 Sign-off on an MOC or task allocated to a state.
There are a total of 40 theoretically possible scoping question
symbols (2 values for “Action Item specified”  2 values for “Role
2
The value of i is constrained so that i ¼ 10s/3. specified”  2 values for “Information specified”  5 action item
504 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510

Fig. 2. Sensitivity of proper MOC scoping to human error metrics.

types [including information-only]). However, in practice, only 15 list of action items. Every MOC goes through a PHA process (usually
scoping question configurations were seen. HAZOP). It’s up to the PHA team to decide what “really” needs to be
The most common kinds of scoping questions symbols are listed done on this MOC. The obvious flaws from this process are:
in Appendix A.
1. the PHA isn’t conducted until after the important drawings are
redlined, so redlining of some design documents may be
3.3. Analysis
overlooked, and,
2. the PHA team is (appropriately) focused on safety, so admin-
The scoping items were analyzed for 15 companies and plotted
istrative aspects of the change (e.g. update the PSV database)
in Fig. 5e7. The symbols are scaled so that the area is proportional
may be overlooked.
to the number of items. For example, a triangle with a base length of
0.100 represents 1 item, while a triangle with a base length of 0.200
represents 4 items. The largest blue triangle for Company N
3.3.3. Inspection as the key to success
represents 221 items; the large information symbol for Company O
Company E also runs a similarly-sized refinery to Company D.
represents 428 items.
The design work is “stateless”; the scoping process does produce
a list of what documents need to be updated, and by whom, but not
3.3.1. Minimalist scoping approach
when the updates are supposed to occur.
Companies A, B and C have a very minimalist approach to MOC.
Recall that Company D used the PHA as the “sanity check” on the
The MOC Initiator creates a list of things to do, guided by a checklist.
MOC; similarly Company E uses inspection as a sanity check on the
Since there’s no indication of who, why or when the action items
MOC. Inspections are identified and scoped at a very granular level,
are to be conducted, we can only assume that the Initiator acts as
project manager and schedules all the tasks individually.

3.3.2. Minimalist scoping: the PHA as the key to success

Company D operates a large refinery. The MOC scoping process
produces action items: what and when are specified, but not who
or why. A review of the MOC procedure reveals that the logic that
this company uses is that the scoping process produces a minimal

Fig. 3. Scoped action item symbol, showing the meaning of the shaded regions. Fig. 4. Color code for scoped action item symbol shading.
 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510 505

Fig. 5. MOC scoping practices of 11 companies.

including making over 100 inspection forms available via the MOC
process.
3.3.4. Always the same approvers
One might wonder why there aren’t any approval actions indi-
cated for companies AeE? The reason is that a specific set of
approvers is specified by the MOC procedure, and the same
approvers sign-off on every MOC. So, the approvers are not selected
by scoping; a standard set of approvers is simply part of the process.
The obvious shortcomings of a static approver list are:
 Not enough approvers: New circumstances may arise, that
require additional approvers. No doubt the extra person (s) are
invited into the process, which is technically a process
exception.
 Too many approvers: Oftentimes, approvers sign-off on MOCs
that have little to do with their specific area of expertise.
3.3.5. Approvals as the key to success
Companies G, H and J all depend on the approvers to assure the
success of an MOC, so a great deal of effort is spent on identify the
proper approvers based on the characteristics of the change.
Company G represents the first rather complete example of
scoping, since action items are created for all states. The MOC
procedure at Company H gathers a lot of information (see large
stateless information symbol), but makes no attempt at scoping the
MOC beyond the reliance on approvers.
3.3.6. Impact Analysis as the key to success
Company K’s MOC process is singularly focused on risk avoidance.
The scoping process identifies lots of things that need to be looked at
during the impact analysis state. Specifically, the scoping activity
identifies items of concern for the PHA, the environmental review, the
personnel safety review, the industrial hygiene review, etc. The
impact analyses are then reviewed by a standard set of approvers.
506 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510

Fig. 6. MOC scoping practices of 4 companies.

Interestingly, the scoping activity doesn’t provide any helpful
guidance on what documents need to be updated, or any activity
that has to be performed.
Company L also has exhaustive questionnaires related to impacts
(especially environmental) of the change. However, the scoping
activity at Company L covers the entire lifecycle, a much better
arrangement than the overly restrictive approach of Company K.
3.3.7. The technical review as the key to success
Company M has one of the lengthiest MOC scoping question-
naires. And, the questions are very complete with full consideration
regarding what needs to be reviewed, by whom, and why. Most of
the scoping activity is focused on identifying the proper technical
reviewers. Compared to Company I, the large green symbol for
Company M indicates that the technical concerns are considered at
a very granular level.
Additional action items, like redlining certain drawings, etc., are
scoped, but there’s no indication of when they are to be done.
Presumably they need to be completed in time for the review?
3.3.8. Perfect MOC scoping is achievable
Company N has the best quality AND most comprehensive
scoping activity, of all those considered. Notice how every scoped
element, whether a call to perform an action (blue), a review
(green) or a notification (yellow) is fully described. There’s a state-
ment of why the item needs to be done, what role is supposed to do
it, what kind of action it is, and when it should be performed. The
symbols in Fig. 6 represent a total of 611 scoped items. Note also

Fig. 7. An ideal, scoped MOC. (For interpretation of the references to color in this figure legend, the reader is referred to the web version of this article.)
 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510
that there are no stateless tasksdevery task is clearly identified as
to when it needs to be performed.
There are no sign-offs (red) because the sign-offs during the
Approval state are part of the process; they are not scoped into the
MOC.
3.3.9. Redlining vs. updating
Normally, MOCs are performed on existing assets in the plant
(or an existing product, etc). Obviously, there are existing docu-
ments which describe those assets. Modification of documents, in
the MOC context, is a two-step process: the documents are first
redlined, generally during the Change Design state; once the
change is made to the plant, the documents are updated, generally
during the Close-Out state.
The processes of Company N, and to a lesser extent J and L,
clearly show this characteristic. There are many action items that
take place during Change Design, and many during Close-Out. The
fact that not every company’s process has these features is an
additional indication of vagueness.
3.3.10. Information as the key to success
Company O has a detailed questionnaire for each MOC. The large
symbol with the black shading in the lower right, in Fig. 7, indicates
that there are 485 information gathering questions that must be
addressed during the scoping activity. The company has structured
the questions sensibly, so that only the relevant categories of
questions are answered during scoping. Someone has gone to a lot
of trouble to put these lists together. Wouldn’t it make sense to
complete the job by identifying associated action items?
To some extent they have done that. There are an additional
couple of hundred scoping questions which do identify actions that
need to be performed. But, as shown by the blue symbols in Fig. 7,
the company didn’t go all the waydspecifically, there’s no indica-
tion of when these actions need to be performed.
To the credit of Company O, the process does produce a good list
of technical reviewers (green symbol) for each MOC.
4. Case study: an ideal, scoped MOC
The quality of scoping, illustrated in the previous section, ranges
from marginal (Company A) to superb (Company N). Most
companies had clearly identifiable gaps in their MOC scoping
approaches. For the record, none of the companies AeO were the
author’s clients, when they created their MOC procedures.
However, the following case study does involve one of the author’s
clients.
The client is a global chemical company. The company has about
100 sites worldwide, a few are quite large (hundreds of employees),
and the majority are quite small (less than 10 people per site).
Highly hazardous chemicals, of the kind found in Appendix A of the
PSM regulations (OSHA, 1992), exist at a few, but not the majority of
sites. Everyone is obliged to use the MOC process, whether they are
at a PSM-regulated site or not. At the start of the project, the
existing MOC procedure was similar to Company H, shown in Fig. 5.
The company had already assembled a team of about 6 key
stakeholders, who participated in face-to-face meetings, with an
additional 5 in Europe who initially participated by teleconference,
but also in-person for the final meeting.
The scoping redesign took place during 3 facilitated team
meetings and individual work in the interim.
The first team meeting was a full day. The team “tore apart” the
existing process. Every item was questioned: what? what kind?
who? why? when? This highlighted data gaps, like the lack of an
official list of units for all the plants.
507
Between the first and second meetings, the facilitator recon-
stituted the scoping process based on the input from the first
meeting. The second meeting was again, face-to-face, but this time
only a half day.
The facilitator presented the updated scoping process at the
start of the second meeting. The team critiqued what the facilitator
had prepared.3
Between the second and third meetings, the facilitator quickly
updated the scoping materials, and distributed them. Each team
member was asked to be extremely critical and identify any scoping
detail that they did not entirely agree with. This feedback was
consolidated, and the final scoping ruleset was updated by the
facilitator.
The third meeting was only 2 h, and really served to ratify the
work that the team had accomplished.
What was the outcome?
Using the evaluation approach, described in the previous
sections, the new MOC scoping approach at this company is as
shown in Fig. 7. In order to make the symbols in all the diagrams
comparable, they are sized to the same scale; that is, a symbol with
a given area in Fig. 7 represents the same number of action items as
a symbol with the same area in Fig. 6.
The new scoping approach at this company incorporates all of
the positive attributes previously identified:
 100% of action items are fully-formed: the action, the type of
action, the role, the reason for the action and the timing are all
specified
All the action items that can be specified4 up-front, are speci-
fied. Little is left to individual’s memories.
 The separation between redlining (blue actions during Change
Design) and document updating (blue actions during Close-
Out) is recognized.
 The quantity and extent of hazards at this company are less
than Company N. So, it’s reasonable that there are fewer
scoping items, as indicated by the area of the symbols in Fig. 7
being smaller than the area of the symbols in Fig. 6.
5. Summary
Proper execution of Management of Change requires that the
action items identified on the MOC form be complete and suffi-
ciently detailed. Although explicit and guided scoping techniques
are commonly used, their ability to produce an error-free list of
MOC action items is poor. Asset-based scoping, in use at several
facilities, is significantly better at creating a list of MOC action items
without any omissions.
Having all the action items on an MOC is not sufficient. It is also
necessary that the action items be detailed, or “fully-formed”, as
labeled in this paper. Despite the obvious merits of fully-formed action
items, a review of 15 companies’ MOC procedures showed that very
few actually produce an adequately detailed list of MOC action items.
There are no insuperable obstacles standing in the way of
a facility developing an accurate and detailed MOC scoping
approachdit simply requires effort. As the case study in the final
pages of this paper shows, it is possible to move to the best practice
in MOC scoping, in a matter of weeks.
3
This meeting was considerably more enjoyable, since it’s always more fun to
critique the facilitator’s work than it is to critique one’s own work (meeting 1).
4
Certain action items, like PHA follow-up items and PSSR punchlist items can
obviously not be determined during scoping, and are added into the process later,
as needed.
508 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510

Appendix A. Common scoped action item symbols

The meaning of several scoped action item symbols.

Symbol Description Samples

This is a fully-formed perform action item: Example 1:

 The reason for the action is stated  Does this change involve a safety critical alarm?
 The action is properly described  Perform a PHA
 The intended role is identified  Process engineer
 When the action is to be performed is identified  During the impact analysis state

Example 2:
 Does this change introduce or modify the inspection frequency
of new or existing equipment?
 Update inspection database
 Mechanical Integrity group
 During the Implementation state

Example 3:
 Will this change exceed the relief capacity of individual pieces of equipment?
 Conduct pressure safety review
 Mechanical engineer
 During Change Design state

This may be termed “explicit scoping”. Example 1:

The statement indicates what needs to be  Redline electrical drawings
done, who should do it, and when to do it.  Electrical Engineer
What’s missing is the reason for the action,  During Change Design
although the reason can often be determined
by the context. Example 2:
 Complete the appropriate piping inspection.
 Inspector
 During Implementation

Example 3:
 Update process flow diagram, by incorporating redlines.
 Process Engineer
 During Close-out

These action items explain what is to be done, Example 1:

why and when. All that’s missing is an  Is the change classified as a major change?
indication of the intended role.  Complete the Activity Screening form.
 During Impact Analysis

Example 2:
 Do the changes in test methods require revalidation?
 Revalidate the test methods.
 During PSSR.

These are commonly expressed as something to do. Example 1:

When the action is to be performed is indicated,  Redline P&IDs
but not why or by whom.  During Change Design

Example 2:
 Assess impact on electrical devices and disconnects
 During Impact Analysis

Example 3:
 Update safe operating limits
 During Close-out

These are commonly expressed as something to do. Example 1:

But there is no indication as to why, who or when?  Update P&ID
Example 2:
 Does the asset database need to be updated?

Example 3:
 Test control system change
 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510 509

Appendix A. (continued )

Symbol Description Samples

This is a fully-formed Review action item: Example 1:

 The reason for the action is stated  Does this change involve placing equipment or
 The action is properly described operators close to flares, fired heaters or other heat sources?
 The intended role is identified  Conduct a review
 When the review is to be conducted  Process Engineering
is identified  During the Approvals state

Example 2:
 Does this change involve increased
waste or pollution production?
 Conduct a review
 Area Environmental rep
 During the Approvals state

Example 3:
 Has the effect of potential contaminants
been evaluated in the design of this relief valve?
 Conduct a review
 Pressure Safety group
 During the Change Design state

This is a well-formed sign-off. It includes an Example 1:

indication of who is to sign-off and why  Does this change modify the relief system design for
they are doing it. any equipment or piping?
 Sign-off
 Engineering Representative
 During Approvals

Example 2:
 Does this change introduce a new chemical?
 Sign-off
 Quality Representative
 During Approvals

Example 3:
 Does this change add, remove or alter
piping or equipment?
 Sign-off
 Mechanical Integrity Representative
 During Approvals

This is a well-formed notification. It includes an Example 1:

indication of who is to be notified, and why they  Notification of utility change: the steam system is
are being notified. being decommissioned
 The person is sent a notification
 Plant Operations
 During Implementation

Example 2:
 Notification that unit is ready to start up.
 The person is sent a notification
 Plant Manager
 During PSSR

This scoping question only provides information. Example 1:

It is not action-oriented.  Critical equipment added to critical equipment list
It’s possible to guess what might be needed, but the
information provided simply doesn’t explain Example 2:  Maximum temperature ____
what is needed.
Example 3:  Does the change add or modify a tank larger than 50,000 L?
510 R. Hoff / Journal of Loss Prevention in the Process Industries 26 (2013) 499e510
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