MOC, Investigation, Emergency Response, and Trade Secrets
Management of Change (MOC)
Many of the catastrophic accidents over the past few decades can be traced, in large part, to a management of change system that was not in place or was not functional.
OSHA believes that contemplated changes to a process must be thoroughly evaluated to fully assess their impact on employee safety and health and to determine needed changes to operating procedures. To this end, the standard contains a section on procedures for managing changes to processes.
Written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures, and change to facilities that affect a covered process, must be established and implemented.
Written PSM procedures must ensure that the following considerations are addressed prior to any change:
- The technical basis for the proposed change,
- Impact of the change on employee safety and health,
- Modifications to operating procedures,
- Necessary time period for the change, and
- Authorization requirements for the proposed change.
Employees who operate a process and maintenance and contract employees whose job tasks will be affected by a change in the process must be informed of, and trained in, the change prior to startup of the process or startup of the affected part of the process.
- If a change covered by these procedures results in a change in the required process safety information, such information also must be updated accordingly.
- If a change covered by these procedures changes the required operating procedures or practices, they also must be updated.
Knowledge Check Choose the best answer for the question.
9-1. Which of the following considerations must be included in written PSM procedures prior to any change?
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