Dealing with Management of Change (MOC’s) for Process Safety Management and Risk Management Planning
Management of Change (MOC) and Change Management are analogous elements for both Process Safety Management (PSM) (29 CFR 1910.119 (l)) and Risk Management Planning (RMP) (40 CFR 68.75). Both are incorporated into PSM and RMP development as one of the 14 elements of each. Simply stated, both are a formalized process for managing change within OSHA’s PSM and EPA’s RMP programs.
“What is MOC or change management?” is best described by bookending what they are not. For example, changing a Pressure Relief Valve (PRV) on a regulated process with the same or, “Like,” PRV would not be an MOC or Change. Instead, it would be a “Like-Kind,” replacement requiring it be recorded in the system logbook. On the other end of the spectrum would be a system expansion or significant safety improvement which would reset the PSM and/or RMP. This would require significant updates to many of the other key elements of PSM and/or RMP necessitating a pre-startup safety review.
MOC and/or CM is neither of the above. Several examples include:
- Changing a PRV with a different updated model.
- Changing a pipe in a system for physical or chemical properties.
- Changing a seal using a different elastomer for physical chemical reasons.
- Etc.
In example 1 above the materials of construction, elastomers if any, and pressure or temperature ranges need checked to make sure there is compatibility with the process.
In example 2 the metallurgy needs to be verified for the new chemical(s) as well as the pressure and temperature.
In example 3 elastomers need to be verified for compatibility with the chemical(s), temperature, and pressure.
For PSM regulated processes and systems, MOC is one of the top four cited violations. MOC’s are required for:
- Processing chemicals
- Changes in the company’s technology
- Changes in equipment
- Changes to company procedures
- Changes to the facilities
MOC’s and/or CMs are a critical part to process safety. The formalized procedure is usually managed using a form that is incorporated into the PSM/RMP programs. Anyone at a facility can initiate an MOC and/or CM but the team responsible can decide to do nothing with an MOC. An example could be reducing the loudness of an alarm because it interferes with hearing. However, most of the alarm levels are set so they can be heard. As such, an MOC and/or CM for this would be rejected.
An MOC and/or CM is reviewed and managed by a team designated by management. The MOC and/or CM also requires reviews and countersignatures indicating review by the person responsible for the system, engineering, and plant management.
A webinar on MOC and/or CM management incorporating key decision points and reviewing a sample MOC and/or CM will be conducted February 16, 2022.
