With the required HAZCOM GHS labeling and SDS training now behind us, I wonder how many PSM/RMP covered facilities actually considered these “changes” to our site chemical labeling scheme something that would warrant a MOC? There are many professionals that would make the argument that an HAZCOM program has nothing to do with PSM/RMP compliance; however, I would like to take the position that changing our entire chemical labeling scheme is one that certainly warrants a MOC… and here’s why.