COVID safety changes may need an MOC when they impact a PSM/RMP process

Social Distancing Devices

Social Distancing DevicesWe 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…

These devices are NOT, and from what I could tell from my research, available in a unit rated for a Hazardous Location (HAZLOC).  Had an MOC been done, the workplace would have had an opportunity to review the impacts on safety and health and hopefully would have recognized these devices are NOT rated for use in these Class I and Class II HAZLOCs.  I have written about other electronic devices used in these HAZLOCs (exercise bands, medical devices, etc.) and these would fall into these grouping of devices.

 

 

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