In OSHA’s fiscal year 2022, Management of Change was the #6 most cited element of the PSM standard. Here is a breakdown of those citations…
30 MOC citations or 7% of all PSM citations in 2022
The #1 MOC element cited in 2022 was 1910.119(l)(1), establish and implement written procedures to manage changes, with 16 or 53% of the MOC citations
The #2 and 3 MOC elements cited in 2022, with 4 or 13% of the MOC citations were
1910.119(l)(4), if a change results in a change in the PSI, such information shall be updated accordingly
1910.119(l)(5), if a change results in a change in the SOPs or SWPs, such procedures or practices shall be updated accordingly
The #4 MOC element cited in 2022 was 1910.119(l)(3), employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process, with 3 or 10% of the MOC citations
The #5 MOC element cited in 2022 was 1910.119(l)(2), procedures shall assure that the following considerations are addressed prior to any change, with 2 or 7% of the MOC citations
The #6 MOC element cited in 2022 was 1910.119(l)(2)(i), technical basis for the proposed change, with 1 or 3% of the MOC citations