I am working on getting all of these RMP NOVs posted but found this one especially interesting…
XXXXXXXXXX did not address the impact of the lock-out of the factory workers in August 2011 and hiring all new replacement workers. Such extensive staffing changes could impact the safety and health of the XXXXX workers and should be included in the MOC review process. Center for Chemical Process Safety (CCPS) Guidelines for Management of Change for Process Safety section 3.4.2 Types of Changes to Be Managed include organizational and staffing changes.
So you have been “warned”, now both OSHA and EPA are on record for issuing citations against staffing changes without the aid of an MOC.
CLICK HERE to see all the citations