However, it's the regulations that define what a change is. "Any modification that touches the process safety information is considered to be a change," added Roy. "Included in the PSI are the information about the chemicals used or produced by your operation, process technologies and process equipment, process flow diagrams (PFD), process piping diagrams (P&ID), process descriptions, risk hazard analysis (PHA), safety requirement specification (SRS), and codes and standards relied on to establish good engineering practice at your facility."
Once requested changes have been reviewed and accepted, the PSSR is used to close the MOC process. After a change is implemented and is running as part of the application, MOC compliance audits are done periodically to check its performance, usually every three years or annually. OSHA also conducts similar program quality verifications (PQVs).
Roy added that laws and agencies regulating the MOC process include:
- U.S. Occupational Safety and Health Administration's OSHA-PSM regulation 29 CFR 1910.119, "Process Safety for Highly Hazardous Chemicals" (PSM), which took effect in February 1992;
- U.S. Environmental Protection Agency's EPA-RMP regulation 40 CFR Part 68, "Risk Management Program for Chemical Accident and Release Prevention" (RMP), in effect since in June 1996; and
- The Canadian Chemicals Producer Association's "The Responsible Care Program" Code of Practice, in effect since 1987.
Other non-regulatory agencies and voluntary industry groups that promote MOC in process safety include the U.S. Chemical Safety Board (CSB), the Center for Chemical Process Safety (CCPS) and OSHA's Voluntary Protection Programs (VPP).
Roy explained that OSHA's minimum requirements for MOC include:
- Establishing written procedures for managing changes.
- Addressing the technical basis of each change.
- Evaluating potential safety and health impact of each change.
- Defining requirements for authorizing changes.
- Updating process safety information.
- Updating operating procedures or practices.
- Informing and training employees and contractors affected before changes occur.
- Considering potential off-site impact of changes.
Roy said there are 14 basic elements to develop and implement a MOC that complies with OSHA's Process Safety Management (PSM) standard. They are contained in its Log 300 document and include:
- 1910.119(c): Employee Participation
- 1910.119(d): Process Safety Information
- 1910.119(e): Process Hazard Analysis
- 1910.119(f): Operating Procedures
- 1910.119(g): Training Procedures
- 1910.119(h): Contractors
- 1910.119(i): Pre-Start-up Safety Review
- 1910.119(j): Mechanical Integrity
- 1910.119(k): Hot Work Permit
- 1910.119(L): Management of Change
- 1910.119(m): Incident Investigations
- 1910.119(n): Emergency Planning and Response
- 1910.119(o): Compliance Audits
- 1910.119(p): Trade Secrets
Besides dealing with each requirement, Roy added that their interrelationships also are important and that OSHA will cross-check to see if they show that the changes have been followed through to completion. "The PSM district offices routinely check three key elements to verify that changes have been implemented," he said. "They are 1910.119(e) Process Hazard Analysis, 1910.119(f) Operating Procedures and 1910.119(g) Training."
Roy added, "There are different ways to apply a MOC process, but the law has these 14 elements, so users must fit their culture within them. There are many new and online tools to help with this, but users must also stay flexible and not get too locked into their tools either."
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"Management of change is not a form. It's a process." Invensys' Ulric Roy explained how change management methodologies work to fulfill OSHA's process safety management requirements.