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.
1. Changes in Equipment Design
Listed are some examples of OSHA citations where an MOC was not utilized when there was a change in equipment design:
■ Installing a control valve bypass;
■ Installing a spill guard berm under a fracturing tank along with proper grounding and bonding;
■ Changes to an alarm set point; and
■ Changes to materials of construction.
If any piece of equipment is changed to equipment with different specifications from the design in the PSI (i.e., not a “replacement-in-kind”), an MOC must be utilized.64 Likewise, changes in design such as chemicals used or increases/decreases in operating parameters
outside their range described in the PSI also require MOC. Such changes may result in new hazards or necessitate new or additional safeguards and/or procedures.
2. Changes in Operating Procedures
OSHA found that some facilities did not utilize MOC when changes in operating procedures occurred. Examples include:
■ Changing procedures for the manual addition of methanol to a chloride injection tank; and
■ Procedures for installing a new type of relief device (different from the original).
If operating procedures are changed, MOC is required to assess the potential hazards introduced by the change. Additionally, MOC ensures that proper training is provided on the new operating procedures to affected personnel before the start-up of the process or the affected part of the process.
3. Changes in Inspection, Test, and Maintenance Procedures
During NEP inspections, OSHA found MOC was not used when there was a change in maintenance procedures. Examples include:
■ Changing inspection intervals for piping circuits;
■ Changing the number of thickness measurement locations (or condition monitoring locations) on a pipe; and
■ Changing maintenance procedures following a change (not replacement-in-kind) in process equipment.
Maintenance procedures will dictate preventive maintenance intervals and repair procedures. Similar to operating procedures, if maintenance intervals or regular repair procedures need to be changed, MOC must be utilized.
4. Changes in Facilities
If an existing structure is being modified (such as upgrading ventilation, changing exit locations, or reinforcing the structure), MOC must be initiated. Also, for newly installed facilities within or near a PSM-covered process, an MOC must be created. NEP inspection OSHA citation examples include:
■ Installing a light wood or metal shed structure near a Hydrocracker Unit; and
■ Changes to a control room located within a PSM-covered process unit.
Employers must initiate MOC for these types of changes.
5. Time Limitations on Temporary Changes
Finally, MOCs were not initiated when there were temporary changes, including when using temporary supports during the installation of a new vesselit, or using a shed or break area as a temporary control room during the or piping circu construction or repair of the main control room.
Temporary changes, which are usually initiated while a permanent change is being made, must be properly assessed through the MOC process for the permanent change. OSHA also found that some employers create MOC procedures that fail to define or fail to adhere to the time limit of the temporary change.67 CCPS notes that “if temporary changes are permitted, the MOC review procedures should address the allowable length of time that the change can exist and the procedure should include a process to confirm the removal of temporary changes or restoration of the change to the original condition within the time period specified in the approved change request.”
Source: https://www.osha.gov/sites/default/files/publications/OSHA3918.pdf