For those who work and live in the world of Process Safety Management, the abbreviation MOC may make you and your colleagues cringe. And when some “consultant” tells you that using the Management of Change (MOC) process for changes to our Emergency Response Equipment, especially PPE, you are probably thinking… SERIOUSLY? I cant keep track of the ones I have open now! (that is another discussion we need to have later). But seriously, there are very few PSM/RMP and S&H audits that we perform where we do not find some serious discrepancies in the Emergency Response Team PPE and how it is being managed. Even just a change in brands of SCBA or LEVEL A suit can change the inspection/care of the PPE as some companies have different inspection/testing frequencies and limitations on their products. For example…
Level A Suits
A facility decides (for whatever reason) to change to their LEVEL A Suits from Brand Y to Brand X. Their former suits, Brand Y, had only an annual pressure test requirement. The new suits, Brand X require pressure tests at three (3) periods dependent on its use (upon receipt, annual, after non-contamination donning) AND they have a different service-life based on contamination factors. Along comes an audit team and we ask to see the inspection and test records for these new suits (Brand X) and all that can be provided are the annual pressure test as were done for Brand Y. In fact, Brand X also requires the two (2) exhaust valves on their suits to be changed out every two (2) years regardless of what the annual visual inspection finds. And I might add, Brand X requires the annual visual inspection of these exhaust valves be done using a magnifying glass when examining the gaskets for cracks!
SCBAs
The facility upgrades from the old 2216 psi cylinders to the 4500 psi cylinders, but the pressures are not the only thing that changed. The old 2216 psi cylinders were “steel bottles” which had no service-life limitations and a 5-year hydrostatic testing frequency. The new 4500 psi cylinders are much lighter hoop-wrapped aluminum cylinders and these come with a hydrostatic test every 3 years and have a 15 year service life – REGARDLESS of inspection/testing results! The facility did “upgrade” their SCBA’s but this “upgrade” was indeed a change that impacted their Emergency Response Plan, Respiratory Protection Program, and their Mechanical Integrity program as it relates to testing their cylinders per 49 CFR 180.209 Requirements for Requalification of Specification Cylinders. So the facility’s work order system was still set to 5-years for their new cylinders which require a 3-year frequency and the inspection checklist being used was for the old 2216 psi cylinder for which the low level alarm sounded at a different psi than the new 4500 psi cylinders.
So as we can see, just simple changes in brand and/or model can have significant impacts on how we manage our high-risk PPE. Not only does our care, use, and limitations change, but these changes may in fact (I would say most certainly will) require some training for those who will be performing these new inspections. At the very least, the programs will need to be revised to show these new requirements and their frequencies and that in and of itself should have triggered thoughts of using the MOC process to help evaluate and manage these changes.
Some may balk at these details and call them minor errors, but both examples are CLEAR violations of OSHA standards (1910.134 and 1910.120). And trust me, when you’re donning your SCBA and LEVEL A suit in preparation to enter a cloud of any HHC/EHS, the last thing you want to be guessing about is their ability to provide you and your partner with the level of protection you need while working in an IDLH atmosphere!
