One of the most popular PSM requests I get is for an example of a “change to facilities that affect a covered process”. In this article, I hope to provide an actual example and how a “change to facilities” can affect an ammonia refrigeration facility. OSHA’s PSM standard states the following about managing changes…
(l) Management of change. (1) The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
In my real-life example I hope to convince many of you that this scenario, which is very common within the food industry, will not only impact your MOC program but your PSSR program as well, as this “change in facilities” at a refrigeration facility (built after 1992) will IMPACT your Process Safety Information as well. Here is what happened: