As I always say, we can not discuss MOC and PSSR as if they are separate systems… they go hand in hand 99% of the time. That is what I want to discuss: how a PSSR requirement defines how we manage our MOC system. We have discussed many times there are ONLY TWO (2) occasions where OSHA and EPA require a PSSR to be conducted:
- new facilities, and
- modified facilities when the modification is significant enough to require a change in the PSI
So when #2 above comes into play, what does OSHA/EPA mean when they say…
“modified facilities meet the requirements contained in management of change, paragraph (l)” (1910.119(i)(2)(iii)