No, it doesn’t involve anything with refrigeration. Same equipment, the same people, and a better layout to improve efficiency. So why would an MOC be required if it doesn’t impact refrigeration/PSM?
Well, we have to think a little beyond equipment changes in the refrigeration system for a moment, or procedural changes, etc. that we normally think about. And while we’re at it, promote team inclusion, and subtly change the safety culture of a facility…
It’s possible that this change in line layout may well impact emergency egress or the ability of the employees to hear emergency notifications. And doing so affects the Emergency Action Plan/Emergency Response Plan. And because Emergency Planning and Response is a PSM/RMP-covered element, we’re bound to at least review the impact the line layout may have.
In truth, if conversations like this happen at all, they happen the day or night before the change. So how do you manage properly performing the MOC? The decision to change that line layout didn’t happen today or this evening… and if we go back to an OSHA interpretation from Chem NEP, 2007
"An MOC procedure is required anytime a change per the requirements of 1910.119(l) is considered."
This was discussed in advance to coordinate maintenance and other trades necessary to effect the change, and that’s where the opportunity lies.
If you always do it the same way, you’ll always get the same results.