We have seen hundreds of changes to our businesses since March and many of these changes were needed for worker protection, but recently we came across one such change that had serious potential to cause a bad event! Maybe you have seen the latest and greatest devices for aiding in our “social distancing” efforts. These devices appear to be marketed towards office and healthcare settings and NOT so much towards chemical processes! But we came across them in use in a PSM covered process and there was NO MOC done – should there have been? Absolutely and here’s why…
COVID safety changes may need an MOC when they impact a PSM/RMP process