OSHA and EPA are now citing for not doing MOCs on personnel changes! The debate rages on for those living in the PSM/RMP world. Just this week, a client called me to help them with an audit finding they received in a third-party audit. The auditor wrote the finding that they were not considering personnel changes in their MOC program. I too often write a similar finding when I come across situations where staffing levels have changed and the change could have significantly impacted process safety. For example, some of the situations I have taken exception with: