For those who live within the process safety bubble, you know all about the MOC “requirements” from OSHA and EPA process safety standards. However, an MOC program is vital to any formal Safety Management System. And you would be correct to say “OSHA (nor EPA) does not require one outside a PSM/RMP standards. But after a busy year helping clients with both traditional occupational safety and health and process safety matters, it became more clear just how critical this tool has become.
In this article, I will use three (3) examples of how a business spent thousands of hours and hundreds of thousands of dollars to correct audit/assessment opportunities, only to find their efforts destroyed by their own lack of “managing changes” within their facility. The level of frustration this has caused these facilities, from senior management down to the line workers, is immense and just UNNECESSARY.
- Control of Hazardous Energy
- Permit-Required Confined Spaces
- Hearing Conservation
Control of Hazardous Energy
In 202, the SAFTENG team conducted 17 audits involving LOTO. Some of these audits were specific to LOTO practices ONLY, and others were our wall-to-wall audits where we get deep into LOTO practices. Out of these audits, the businesses discovered many opportunities to improve compliance with 1910.147. In 2023, we should expect FULL compliance with OSHA’s standards. Six of the 17 facilities received A+s, four received Bs, and all the others failed spectacularly.
But here is the catch… those companies who got their audits earlier this year asked us to come back for a day or two to review their corrective actions and ensure they are on the right path. The work these facilities put forth to exceed OSHA compliance expectations was extraordinary; however, it took us less than a day to identify additional gaps THAT WERE NOT PRESENT during our initial audit(s). New machines had been installed, existing machines had been moved or modified in place without any updates to their specific LO procedure(s). So essentially, they were ticking off the findings from the audit and could not see the forest for the trees!
Not managing changes will come back to bite us in the _ss! The work these facilities had done corrected their identified deficiencies, yet because they did not utilize their MOC tool, new deficiencies were identified in less than 12 months. In a couple of years, the level of deviation from their own written program would be immense.
Permit-Required Confined Spaces
In our wall-to-wall audits, we can almost bet our houses that we will find spaces that have not been evaluated and are PRCSs that are not identified as such. The facilities all have a practice that maintains an “inventory” of their CSs and PRCSs. These inventories are usually ripe for lack of updates. And like the LOTO situation discussed above, it does not take long to find a space that has not been inventoried, evaluated, and labeled as a PRCS. Almost every time, the safety team was unaware of this vessel’s presence within the facility. And yes, this happens most often within the battery limits of their PSM/RMP-covered process(s). Sometimes, an MOC was done; however, the fact that the change involved a process vessel that needed a PRCS evaluation was overlooked in the MOC. But most of the time, we come across manufacturing equipment that is a PRCS and was never inventoried, evaluated, and labeled as such.
This error can lead to severe consequences, as we almost always interview the workers in the area to see if they can recognize the equipment as a PRCS, and as you can imagine, the vast majority can not, which conjures up some scary thoughts of what can happen. In this day and age, with the level of changes taking place in manufacturing facilities, it does not take long to take an A+ program to a D- level.
Hearing Conservation
Most facilities have noise problems, which forces them to have a hearing conservation program. Even those who may have started up their facility without a noise issue are probably facing one today. However, OSHA’s HCS (1910.95) requires us to reevaluate the noise levels when changes to the work area could increase the noise exposure. This could involve changes that increase the noise levels, or it could include changes to work shifts that cause workers’ exposures to rise (e.g. changing from an 8-hr shift to a 12-hr shift).
1910.95 states the following:
1910.95(d)(3) Monitoring shall be repeated whenever a change in production, process, equipment or controls increases noise exposures to the extent that:
1910.95(d)(3)(i) Additional employees may be exposed at or above the action level; or
1910.95(d)(3)(ii) The attenuation provided by hearing protectors being used by employees may be rendered inadequate to meet the requirements of paragraph (j) of this section.
Not many managers or engineers outside the safety profession could make a correct judgment call on these changes, so it becomes imperative that the safety team be made aware of any proposed changes to the working areas or the shift schedules. The MOC tool allows for this discussion and evaluation to take place and be documented. We have also seen changes made to hearing protection devices that were made in good faith but, in fact, caused increased exposure. Purchasing personnel are challenged to save $, and when salespeople offer PPE at reduced prices, this can be a trap that could go undetected and lead to workers being overexposed.
So there are three basic programs that nearly every manufacturing facility deals with and examples of how changes within the facility could lead to compliance issues and real increased risks. The MOC tool is the answer to managing CHANGES, but it takes a mature management group that has high safety expectations to use this tool faithfully.
