Just mention the letters “MOC” to an engineer or manager at a PSM/RMP facility and watch the eyes roll, the sighs let out, the clearing of throats, and so on. MOC is probably in the top three of the most despised elements of PSM/RMP; and yet, to no safety professionals surprise, failure of doing an MOC has found its way into almost every PSM/RMP related incident or audit report since the inception of the PSM standard back in the early 90’s. Facilities absolutely hate the thought of doing an MOC and often times do not do one or the one they do is grossly inadequate. Most facilities have come to grips with the MOC process and physical changes they make to their process; however, when it comes to doing an MOC on changes to procedures, it is an entirely different story. In this article I hope to explain just what “procedures” would require an MOC when they are revised or even when they are initially implemented.
1910.119(l)(5) states “If a change covered by this paragraph results in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices shall be updated accordingly.” For the record, paragraph (f) is the Operating Procedures element of the PSM Standard. So it is pretty clear that any change to our procedure(s) for Initial start-up, Normal operations, Temporary operations, Emergency shutdown , Emergency Operations, Normal shutdown, and Start-up following a turnaround, or after an emergency shutdown must undergo a review using the Management of Change (MOC) process. Most facilities are coming around to this requirement, although we still see too many not doing an MOC on revisions to their SOPs. Management needs to realize this is such an EASY AUDIT finding for 2nd and 3rd party auditors and especially skilled OSHA CSHO’s. Give me 30 minutes with your SOP’s and MOC’s and I guarantee I can find multiple deviations at most facilities. All I do is look at revision dates on the SOPs and then ask to see the MOC for the revision. If the revision was not an actual change then NO MOC would be needed, but often times SOPs are revised because of a PHA recommendation, Investigation, or it is a new procedure and these should be able to be tracked to closure with an MOC.
What is not “concrete” within the PSM/RMP world is doing an MOC on changes to our Safe Work Practices! Paragraph (f) also specifically mentions the following safe work practices: lockout/tagout, confined space entry, opening process equipment or piping, and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. To me and many of the OSHA folks I work with, these are CLEAR CUT items that would require an MOC for their revision. How many facilities actually have a written procedure to control entrance into a PSM/RMP covered process by anyone other than the operators and maintenance personnel permanently assigned to the process, much less do an MOC when the procedure is revised. We have seen a recent increase in facilities having written procedures to enter a plant site due to the DHS Chemical Security Standards taking place – but these are different than controlling access in to and out of specific process areas. Many safety professionals and almost all operational and maintenance personnel disagree with me and my team on this, but it is written about as clear as OSHA can write it… change one of these safety procedures/safe work practices that are specifically spelled out in paragraph (f) and a MOC is required!
I will even go out on a limb and SUGGEST that there are plenty of other safety procedures that NEED to go through a MOC review if they are every revised or implemented. These receive tremendous push back in our 3rd party audits; but, I am pleased to say the businesses we work for tend to see the value in doing an MOC, not for OSHA’s sake – but rather they have seen the value in the MOC process. We sort of got a taste of the medicine when OSHA published the Refinery PSM NEP nearly two years ago (2009). I am going to go away from the OSHA minimum requirements and suggest the following procedures, when applicable to a process, NEED AN MOC when they are revised or implemented:
1) Emergency Action Plan
2) Emergency Response Plan
3) Fire Prevention Plan
4) PPE Hazard Assessment for PSM related tasks (e.g. sampling, handling covered chemicals, etc.)
5) Respirator Program (especially if operators and maintenance where them in their duties and if not so, if you have a response team because of your PSM/RMP chemicals and respirators will be worn in an emergency)
6) Electrical Safety Related Work Practices (Shady area, but if your PHA identifies electricity as a “critical utility” we go to the point that any work on that utility becomes PSM work, therefore any program that directs that work is a PSM procedure)
7) Fire Brigade’s Organizational Statement
8) Crane and Forklift programs if cranes or forklifts are involved in the ‘”use, storage, manufacturing, handling, or the on-site movement” of PSM/RMP chemicals
9) Hotwork Program & Permit
10) Maintenance Procedures for working on PSM/RMP covered equipment
11) Contractor Safety Management Program
12) Blood Borne Pathogens program for the ERT
13) HAZCOM program
and on rare occasions, when one of the covered chemicals is one of the OSHA listed chemicals found in 1910.1003 thru 1910.1052, the management program required by these standards would also need an MOC for their revision.
The PSM/RMP standards were a GREAT START for chemical process safety, but as many of the CSB investigations have noted, there is room for improvement in both of these safety standards. We should not wait for OSHA or EPA to close these loop holes, but rather we should work to see the value in using a change management system to ensure that ALL changes that can impact process safety AND worker safety under go a THOROUGH review by the PROPER personnel before being implemented. Then we can use the change management system to track the change as it is rolled out to ensure nothing or no one falls through the cracks.