That is PSM lingo for…when you are utilizing Risk Based Inspection (RBI) protocols and you wish to extend the inspection or PM frequencies on a piece of covered equipment, this is without a doubt a change that REQUIRES an MOC.
Evidence…from an OSHA LOI dated 10/31/96
Question 3: Do the management of change (MOC) provisions of the PSM regulations apply when maintenance procedures are changed? Would the MOC process be required for changes made to equipment test and inspection frequencies?
Response: 1910.119(l)(1) requires that the employer 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. According to Paragraph 1910.119(l)(1), except for replacements in kind (please see definition in 1910.119), the management of change (MOC) provisions, l(1) through l(5), would apply to changes in maintenance procedures and for changes made to equipment test and inspection frequencies. OSHA believes that it is necessary to thoroughly evaluate any contemplated changes to a process to assess the potential impact on the safety and health of employees and to determine what modifications to operating procedures may be necessary. Please refer to 1910.119(l)(2) for the considerations that must be addressed prior to any change.