Yes, as many of you have figured out I am a big fan of using the Management of Change process to actually manage changes that may officially be outside the PSM/RMP requirements. But how OSHA changing their injury/illness reporting requirements impact my Process Safety Management System? Here’s how…
A lot of PSM/RMP facilities have a formal incident investigation procedure/program so as to comply with 1910.119(m) Incident Investigation and many of these procedures/programs also contain the OSHA reporting procedures should the facility suffer a “catastrophic” incident. Seeing how this procedure/program is REQUIRED to be in place for PSM/RMP compliance, it is my opinion that a change to this procedure/program should be managed via the MOC process. This change will NOT only involve changing the “text” in the procedure, but we will also have to retrain managers and supervisors of these new reporting requirements. So this change may be a bit more than many have anticipated in how it may impact our PSM/RMP procedures/programs.
Keep in mind that 1910.119(l)(1) states…
The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
Now I realize that a change to the incident investigation procedure or an OSHA reporting procedure may not have a direct impact on the covered process(s), but I encourage clients to use the tools available to them to manage their changes more efficiently. Using the MOC process will aid in identifying all personnel who need to be trained on these changes, maybe there are postings out in the plant that needs to be updated, does the Emergency Action or Response Plan need to be updated with these new requirements? etc. This is what an MOC process is designed to do for us… lay out the change and CONSIDER all the people, documents, equipment, etc. that it may IMPACT and then implement the change in a manner that PREVENTS anything and anyone from “falling through the cracks”.