Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
Management of Change (MOC) Procedure
Rev No. Reason for Revision Prepared By Checked By Approval by
Rev No. R&P Sub-
First release D R Kamath Vijay Chourey
00 committee
Navendra Singh
Rev No. Standardization of
(Head – Corp Safety Vijay Chourey
01 procedure Sudhir Kumar
Operation) (Chief – Corp Safety)
(Corporate Safety)
Navendra Singh Rajesh Sharma Suresh Khetwani
Head- Safety (T&D) Head- Safety Chief - Corporate
Rev 02 Periodic Revision Corp safety (Generation) Corp Safety & Environment
safety
Navendra Singh Rajesh Sharma Suresh Khetwani
Head- Safety (T&D) Head- Safety Chief - Corporate
Rev 03 Periodic Revision Corp safety (Generation) Corp Safety & Environment
safety
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
Contents
Section Description Page No.
1.0 OBJECTIVE 3
2.0 SCOPE 3
3.0 EXPECTED RESULTS 3
4.0 ACCOUNTABILITY & RESPONSIBILTIY 3
5.0 GLOSSARY/ DEFINITIONS 4
6.0 PROCEDURE 5
7.0 RECORDS 6
8.0 TRAINING & COMMUNICATION 8
9.0 VERIFICATION 6
10.0 EXCEPTION 6
11.0 REFERENCES 6
12.0 REVIEW 6
13.0 ATTACHMENTS/APPENDIX 7
-- Annexure – 1: Management of Change (MOC) Form 8
(TPSMS/GSP/MOC/007/FORM/01)
-- Annexure – 2: Checklist for Closure/regularization of 10
Approved MOC (TPSMS/GSP/MOC/007/FORM/02)
-- Annexure – 3: Illustration / case studies of incidents 11
caused due to Failure of MOC
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
1. OBJECTIVE:
The objective of this document is to establish the procedures necessary to ensure that HSE
risks are managed to an acceptable level in Tata Power Management of Change (MOC)
process.
2. SCOPE:
This procedure applies to all operating plants and project sites of Tata Power Group
companies including JVs/Subsidiaries.
Exclusion: Changes applicable to manpower are not covered through this procedure.
These to be covered as per HR procedure.
3. EXPECTED RESULTS:
3.1. Manage all permanents and temporary changes with acceptable level of risk.
4. ACCOUNTABILITY & RESPONSIBILITY:
4.1. ACCOUNTABILITY: Concerned Division’s Heads/Assets Custodian.
4.2. RESPONSIBILITY:
4.2.1. Chief Safety Officer:
4.2.1.1. Be the approval authority and custodian of this document, which shall
include coordinating regular reviews and updates and all supporting
documents.
4.2.1.2. Be the Technical Authority in Tata Power for this Technical Guidance in case
of conflicts between Tata Power divisions and/or external
contractors/consultants.
4.2.1.3. Ensure this Technical Guidance document is effectively implemented and
maintained at all levels within the organization and ensure the contents of this
document are adapted to meet change as necessary.
4.2.2. Division Heads:
4.2.2.1. Ensure necessary action as per this document is effectively implemented and
maintained within their business area and ensure the contents of this
document are adapted to meet change as necessary.
4.2.2.2. Ensure reviews are identified and planned well in advance with sufficient time
and resources allocated.
4.2.2.3. Provide adequate support and resources to effectively implement the
requirements of this document.
4.2.3. Line Managers:
4.2.4. Initiate the process for Management of Change and follow the required
procedures as mentioned in this document.
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
5. GLOSSARY/ DEFINITIONS:
Controls: Methods used to manage safety risks. Controls can be Elimination, Substitution,
Engineering controls, signage/warnings and /or administrative controls, Isolation/
separation, PPE.
e-MOC: MOC initiated through SAP Platform.
Job Safety Analysis: Job safety analysis (JSA) is a procedure which helps integrate
accepted safety and health principles and practices into a particular task or job. In a JSA,
for each basic step of the job, it is to identify potential hazards and to recommend the
safest way to do the job.
Hazard: Source or situation with potential for harm, something that can cause body injury /
occupational illness, damage property.
Hazard Identification & Risk Assessment: Hazard Identification & Risk Assessment is to
identify and evaluate the hazards, Risk and put controls measures for safe execution of
activities.
Job: A piece of physical work defined by time or other limits and that has a clear start and
end point
MOC: Management of Change
Management of Change: Any Modification/change/replacement pertaining
plant/equipment/Machines/structure which is Replacement not–in–Kind (RNIK) to
previous one (for example replacement of any new spare which is not similar to previously
used spare, replacement of outdoor switchyard with Gas Insulated switchgear (GIS),
Changing route of pipelines, modifying set values of Safety devices like safety valve etc.).
Non Routine Job / Task: Where an SOP / SMP is not available or the conditions of the
SOP / SMP have changed
Replacement not–in–Kind (RNIK): Replacement of any new spare which is not similar to
previously used spare.
Replacement in–Kind (RIK): Replacement of any new spare which is similar to previously
used spare, may be change in brand/manufacturer.
Risk: Effect of uncertainty, Risk is a combination of the consequences of an event and the
associated “likelihood” of occurrence.
Risk Assessment: A systematic and structured process whereby hazards present in a
workplace, or arising from workplace activity, are identified, risks assessed / evaluated,
and decisions prioritized in order to reduce risks to acceptable levels.
Severity: The level of consequence / harm of an event that could occur due to exposure
to the hazard present
Shall: Mandatory requirement
Should: Optional requirement
Statutory requirements: Laws, regulations applicable at the location of plant /work.
Task / Activity: A sequence of steps taken to conduct a job. A task is a sub element of a
Job.
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
6. PROCEDURE:
6.1. Recognizing and Initiating the change process:
6.1.1. The following may typically be considered (not all inclusive) as a change that
may have an impact on HSE performance when not managed properly:
6.1.1.1. Replacement Not–in–Kind (RNIK)
6.1.1.2. Design Changes in plant/equipment/Machines
6.1.1.3. Changes to structure
6.1.1.4. Operations & technology changes
6.1.1.5. Changes in procedures
6.1.1.6. Safety system changes
6.1.1.7. Other changes like but not limited to innovation leading to improvement in
process/methodology/time/safety etc.
6.2. Types of MOC:
6.2.1. Temporary MOC: Any MOC for maximum period upto six month.
6.2.2. Permanent MOC: Any MOC which shall be valid without any limitation of time.
6.3. Steps for initiation, approval and implementation of Management of Change (MOC):
Following steps shall be adhered any change where this procedure is applicable. Refer
Annexure – 1 for “Process Flow Diagram (PFD) for initiation, approval and
implementation of Management of Change (MOC)” for more details.
6.3.1. All MOC request shall be initiated from respective engineers/Heads seeking for
Change.
6.3.2. MOC shall be initiated as per Annexure-1 Management of Change (MOC)
Format (TPSMS/GSP/MOC/007/FORM/01).
6.3.3. MOC request shall be commented by R&P SIT Chairman of concern division. He
may further take inputs from Rules & Procedure Sub-committee if required. He
alongwith consultation of division safety team will identify list of
departments/agencies to involved for review and inputs for the proposed MOC.
MOC request shall be forwarded to all such departments/agencies for their review
& inputs. All such inputs received shall be considered as appropriate while doing
risk assessment for the proposed change.
6.3.4. Detailed Risk Assessment for the risk arises due to MOC shall be carried out and
additional control measures shall be mentioned. Risk assessment reviewed by
Division Safety Head and approved by Divisional Chief shall be attached with MOC
request.
6.3.5. Temporary MOC request shall be approved/rejected as appropriate by concern
Divisional Chief/CEO.
6.3.6. Permanent MOC request shall be cleared and commented by concern Divisional
Chief/CEO.
6.3.7. Permanent MOC shall be forwarded along with approved risk assessment for
review of Corporate safety team.
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
6.3.8. MOC request should be forwarded with recommendations from corporate safety
within seven (07) working days to concern Divisional Chief/CEO.
6.3.9. Permanent MOC shall be reviewed and approved/rejected by concern Divisional
Chief/CEO as appropriate
6.3.10. Temporary MOC shall be deemed expired automatically after six months. New
MOC request shall be initiated in case same MOC required further extension.
However extension of MOC shall not be permitted for more than two consecutive
approvals for same MOC and it shall be considered as permanent MOC and shall
be forwarded to concern Divisional Chief/CEO for review and approval.
6.3.11. Implementation of approved MOC shall be done strictly within the scope of
approval of that MOC. This shall be confirmed by implementation team in writing
and approved by Division Chief/CEO. In case of change of scope during
implementation or later stage, modified MOC request to be initiated.
6.3.12. After implementation of approved MOC; checklist shall be filled for closer /
regularization as given in annexure 2 (TPSMS/GSP/MOC/007/FORM /02)
6.3.13. For all MOC involving Capex should undergo PSSR (Pre start up safety
review) after completion but before taking into operation. (refer
TPSMS/GSP/PSSR/010 Pre Start-up Safety Review Procedure)
7. Records:
7.1. Permanent & temporary Approved & Implemented MOC (TPSMS/GSP/MOC/007
/FORM/01) along with risk assessment - Retention period five (05) years
7.2. Checklist for Closure/regularization of Approved MOC (TPSMS/GSP/MOC/007/FORM
/02) Retention period three (03) years.
8. Training & Communication: Training of MOC Procedure shall be included and covered in
Safety Training Calendar as per Safety Training needs.
Initial Communication to be done through Corporate Communication, Email and
subsequently shall be made available at safety portal at Sangam.
9. VERIFICATION: Verification of implementation shall be done during Safety audit, field
safety visit and site inspections.
10. Exception: Any exception to this procedure shall only be done as per Document
Control .Procedure (TPSMS/GSP/DC/014).
11. REFERENCES
• Tata Power Safety Management System (TPSMS) Manual
• EPM 01.08.07 - Management of Change Process
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
• OHSAS 18001:2007.
• Tata Health & Safety Management System (THSMS)
12. Review:
12.1. Review of this procedure shall be done as and when but not later than once in
every three (03) years. Typical Factors like Changes in legislation, Review of Incident
Reports, Inspection & Audit findings, Feedback from users, Recommendations in
Incident investigation reports may be inputs for the review and revision of the
procedure.
12.2. In case release of revised procedure gets delay due to obtaining feedback or
any other reasons, safety advisory may be issued immediately to take precautions for
the proposed changes in the procedure and revised procedure should be released
subsequently.
13. ATTACHMENTS/APPENDIX :
Annexure – 1: Management of Change (MOC) Form (TPSMS/GSP/MOC/007/FORM/01)
Annexure – 2: Checklist for Closure/regularization of Approved MOC
(TPSMS/GSP/MOC/007/FORM/02)
Annexure – 3: Illustration / case studies of incidents caused due to Failure of MOC
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
TPSMS/GSP/MOC/007/FORM/01 Annexure - 1
Management of Change (MOC) Form
SECTION-I:
(TO BE COMPLETED BY THE CONCERN DIVISION/JVs/ SUBSIDIARY)
Name of DIVISION/JVs/ SUBSIDIARY: ____________________
MOC Number: ____________ DATE: _______
Brief description of Change proposed :______________________________________
Location of plant/detail of equipment/Machine for subjected to change:
______________________________________________________________________________
Type of MOC: Permanent/Temporary (Strike our which ever not applicable),
Duration in case of temporary Change:___________(not more than 6 month)
Justification/Explanation for need of MOC (use additional Sheet if required):
___________________________________________________________________________
• Attached approved Risk Assessment? Yes/No
• Environmental, health, and safety reviews are complete and all concerns have been addressed.
(Yes / No)
MOC Initiator Name & Sign: _____________________ Date: ____________
Remark &sign by Division R&P SIT Chairman:
____________________________________________________________________________
Remark & sign by Division Safety Advisor: _____________________________________________
____________________________________________________
Accepted/ Accepted with Comments/Rejected (in case of Temporary MOC)
Comments By Division Chief (in case of Permanent MOC)
____________________________________________________________________
_____________________________________________________________________
Sign & Name of Divisional Chief Date: ____________
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
SECTION-II:
(Applicable for permanent MOC only )
Safety Comments/Recommendations (use additional sheet if required):
_________________________________ Date: ________
Chief- Safety/Corp Safety Rep.
Permanent MOC Accepted/ Accepted with Comments/Rejected:
-
Date: ________
_________________________________
Division Chief/CEO
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
TPSMS/GSP/MOC/007/FORM/02 Annexure - 3
Checklist for Closure/regularization of Approved MOC
S. Yes/ No/
Checks Points Remarks
No NA
1. Applicable Operating, maintenance and emergency
procedures have been reviewed.
2. Concern persons involved/affected due implementation of
approved MOC are trained.
3. Legal & Other requirements register updated as applicable
4. Concerned drawing (P&ID etc.) are revised and updated.
5. Whether MOC implemented as per approved MOC documents.
6. Approved copy (duplicate) sent to R&P Sub committee and
mail copy kept at division level.
7. Affected Site Housekeeping/restoration maintained after
implementation of MOC.
8. Safety signage updated as applicable.
9. PSSR carried out (in case of MOC involving Capex)?
10. Learnings captured and shared concerned divisions/
departments, Corporate Engineering and Corporate safety?
11. Any other
MOC Initiator Name & Sign: _____________________ Date: ____________
Division R&P SIT Chairman: Name & Sign: __________________ Date: ____________
Division Chief: Name & Sign: _____________________ Date: ____________
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
Annexure - 3
Illustration / case studies of incidents caused due to Failure of MOC
Case Study 1: Flixborough Disaster
At about 16:53 hours on Saturday 1 June 1974 the Nypro (UK) site at Flixborough was
severely damaged by a large explosion. Twenty-eight workers were killed and a further 36
suffered injuries. It is recognized that the number of casualties would have been more if the
incident had occurred on a weekday, as the main office block was not occupied. Offsite
consequences resulted in fifty-three reported injuries. Property in the surrounding area was
damaged to a varying degree.
Prior to the explosion, on 27 March 1974, it was discovered that a vertical crack in reactor No.5
was leaking cyclohexane. The plant was subsequently shutdown for an investigation. The
investigation that followed identified a serious problem with the reactor and the decision was
taken to remove it and install a bypass assembly to connect reactors No.4 and No.6 so that the
plant could continue production.
During the late afternoon on 1 June 1974 a 20 inch bypass system ruptured, which may have
been caused by a fire on a nearby 8 inch pipe. This resulted in the escape of a large quantity
of cyclohexane. The cyclohexane formed a flammable mixture and subsequently found a
source of ignition. At about 16:53 hours there was a massive vapour cloud explosion which
caused extensive damage and started numerous fires on the site.
Eighteen fatalities occurred in the control room as a result of the windows shattering and the
collapse of the roof. No one escaped from the control room. The fires burned for several days
and after ten days those that still raged were hampering the rescue work.
The control of plant modifications
As already described, the temporary pipe was installed very quickly, to restore production, and
there was no systematic consideration of the hazards or consequences. One of the main
lessons to be learned is that no modification should be made until it has been authorized in
writing by a competent person who should normally be professionally qualified, and that before
giving that authorization the competent person should try to identify all the consequences and
should specify the change in detail. When the modification is complete and before it is
commissioned he should inspect it to see that his intentions have been followed and that the
modification ‘looks right’. In particular, the modification should be made to the same standard
as the original design and this standard should be specified in detail. In addition, there should
be a guide sheet or check list to help the competent person identify the consequences and a
training programme is needed to convince people that the modification control procedure is
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Document Title
The Tata Power Company Ltd Management Of Change
(MOC) Procedure
Document No: Date of Issue: 01/04/2022
TPSMS/CSP/MOC/013 REV 03
necessary. As with all procedures, regular monitoring is needed to make sure that the
procedure is being followed.
A proper Management of Change (MOC) procedure could have prevent this accident. Any
modification should be designed, constructed, tested, and maintained to the same standards
as the original plant.
Case Study 2: Ash Handling (Wagon Loading) Platform, Jojobera Power Plant
One lost workday (Fatal reportable) accident occurred in Jojobera power plant while unloading
fly ash bag from his truck moved for next trip for loading. Driver lost control on vehicle and it
got turn towards right side of the platform (toward the wall side) and hit one person was
present along with his bicycle parked. The injured person was immediately rushed to the MGM
Hospital for treatment where he was declared dead.
The bicycle parking and water point were provided nearby edge of loading platform without
considering its impact as this platform was already in use for unloading and truck movement.
Management of Change (MOC) were not followed prior installation of water points and bicycle
parking stand in view of truck movement in the same location. This incident was occurred
because of failure of adherence to Management of Change (MOC) procedure.
Case Study 3: Incident at Saki Sub Station
A Metal halogen light fitting was installed on the fence. The body of the fitting got short, as the
Light fitting was mounted on the fencing and, the fencing became live. Main Gate of Saki was
replaced during the Ongoing Project. During replacement, Earthing of Main Gate and a part of
fencing (Between two Gates) disconnected. Due to which one person got electrocuted.
A proper Management of Change (MOC) procedure could have prevent this accident. Any
modification / change should be constructed, and maintained to the same standards as the
original.
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