Managing your PRCS Entry Program/Procedures at a PSM/RMP covered facility

How much do you utilize your Management of Change (MOC) tool?  Usually, when the acronym MOC is even whispered, many people begin to roll their eyes, sigh, and in some cases become physically angry. This is one of the mysteries I hope to solve before my retirement – why would anyone dislike a tool that is provided to merely aid in managing “changes”. Why the hostility toward a tool? To start with, unfortunately, most do not view the MOC process as a “tool” but rather a series of paperwork burdens that one must navigate to “get their job(s) done”. This article will demonstrate just how far we should be utilizing our MOC tool to manage changes, specifically changes to our safe work practices such as changing to a new brand and model of direct-reading instrument(s).

Let me start with mentioning the specific safe work practices that OSHA and EPA mention in their process safety standards:

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