March 31, 2009
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
THROUGH: DONALD G. SHALHOUB
DEPUTY ASSISTANT SECRETARY
FROM: RICHARD E. FAIRFAX, DIRECTOR
DIRECTORATE OF ENFORCEMENT PROGRAMS
SUBJECT: Management of Organizational Change
This memorandum addresses the application of 29 CFR 1910.119 (l), Process Safety Management (PSM) – Management of Change (MOC), to covered processes potentially impacted by changes in facility organization, staffing, and policies (Organizational Changes). It does not add to or modify the types of changes subject to MOC; rather, it is intended to increase CSHO awareness of potential sources of changes covered under the PSM standard. The MOC provisions of the PSM standard apply only to changes, including organizational changes, that impact safety in PSM covered processes.