PetroStreet

What are the best practices to control whether a work permit applied for a job does not actually need a change review (MOC process)?
Is it something what Operations (permit issuing authority) is required to control?
Or is there any other barrier before permit issuer verifies?

Now this understanding is quite common that the filter to apply over a work to be done at site is actually a change or not stands with Operations, and logically, that is where exactly one would get to know that someone is actually to change something to the plant assets.
However, that should not be the only filter. Operations should be supported with a review conducted by a team within the site or outside to look for any changes applied without a review process. At our site, two times in a year, a team is made to perform this check through running the work permits, and the work orders executed. They also look into the work orders raised by Operations themselves in addition to other sections like Inspection. That team is our Operations MOC taking this responsibility but still depending on Operations on day-to-day basis to STOP any work involving any change without review approval available.

It is something very interesting to discuss!

Operations, particularly the Permit Issuer, is often in a prime position to identify when a requested work permit might actually represent a change that requires MOC. This is because they are directly involved in approving the specific task being requested and have intimate knowledge of the current operational state.

Key aspects of Operations' role in this verification include:
Reviewing the Scope of Work: When reviewing a permit application, Operations should scrutinize the described work. If the work involves deviating from standard operating procedures (SOPs), modifying equipment beyond routine maintenance, or introducing new materials or methods, it could signal a need for MOC .
Challenging Deviations from Norms: If a permit request seems unusual, requires non-standard steps, or proposes work that deviates significantly from established safe work practices, Operations should flag it for further review. This proactive questioning can uncover potential MOC triggers .
Understanding MOC Triggers: Operations personnel should be trained on what constitutes a change that requires MOC. This includes understanding that modifications to equipment, processes, procedures, or even significant changes in personnel affecting safety protocols, necessitate an MOC review .
Escalation Protocol: If Operations suspects that a permit job represents a significant change, they should have a clear protocol for escalating the request to the MOC review team or relevant safety personnel. This ensures that the change is formally assessed before any work begins .

I would still say that, while the MOC process itself might be managed by a dedicated MOC team or safety department (it is HSE itself in our case), Operations plays a crucial gatekeeping function by identifying potential triggers during the PTW application review. Their direct involvement with operational activities makes them a vital first line of defense in ensuring that all significant changes are properly managed.