The Management of Change (MOC) section of the PSM standard requires the employer to implement written procedures for managing changes (except for replacements in kind) to processes involving chemicals, technology, equipment, procedures, and changes to facilities that affect a covered process. The MOC procedure requires descriptions of the technical basis for the change, impact on safety and health, modifications to operating procedures, the necessary time period for change, and appropriate authorizations. Any employee who the change will impact must be informed and trained appropriately before the unit/process can restart.
During NEP inspections, OSHA found MOC non-compliance for changes in:
(1) equipment design,
(2) operating procedure,
(3) regular maintenance/repair,
(4) facilities, and
(5) excessive time limits for temporary changes.