With the required HAZCOM GHS labeling and SDS training now behind us, I wonder how many PSM/RMP covered facilities actually considered these “changes” to our site chemical labeling scheme something that would warrant a MOC? There are many professionals that would make the argument that an HAZCOM program has nothing to do with PSM/RMP compliance; however, I would like to take the position that changing our entire chemical labeling scheme is one that certainly warrants a MOC… and here’s why.
Let’s look at everything this HAZCOM labeling change will impact:
2) some facilities may have to update their Emergency Response Plans as many plans contain chemical information.
3) who needs to be trained in the new labels and SDS’s?
4) We need to contact our off-site responders for Fire, HAZMAT, and Rescue to ensure they are aware of these changes and what they mean. Keep in mind that many of the government responders in Federal OSHA states will NOT be required to get the HAZCOM training you did in December 2013 so these labeling changes may be VERY NEW and CONFUSING to them.
5) Contractor safety training program may have to be revised. Contractors should have already been trained in the changes by their employer, but if their employer decided to go with the new GHS labels, be prepared for some confusion. I am thinking of the hundreds of site-specific contractor safety videos I have developed, or watched, that contain images of labels and how many will have to be REVISED now!
7) Think of all the PSM/RMP related documents (SOPs, Maintenance Procedures, etc.) that may contain references to chemical labeling details that may need to be updated.
8) If your Process Safety Information uses an MSDS for the chemical information and the current MSDS does not meet the new 16 section data requirements, this MSDS will need to be updated (i.e. update to PSI???)
So as you can see, this labeling scheme change can impact a lot of workers/responders. And to make the connection that this labeling change may need a MOC. How one could not make the argument this is not a PSM/RMP change “to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process” would be hard to argue! Lastly, let us not forget that our MOC program/process is a TOOL to aid us in evaluating the change will have on safety and health and to manage the change so that item and people do not fall through the crack(s). This HAZCOM labeling change is a massive change that impacts EVERY worker on site and a MOC would aid in our ability to manage these changes properly.