This trick is so simple and so few take advantage of it! Hopefully your facility is implementing the Management of Change (MOC) and Pre-Startup Safety Review (PSSR) elements. If you have an audit coming up, there are certain things I can guarantee will be caught by the inspector. I like to call these items “low hanging fruit.” Things like past due pressure relief valves, obvious signs of uniform or pitting corrosion, or an ammonia odor in the machinery room are all sure to be noticed by any inspector. Another item I would classify as low hanging fruit for an auditor is open and past due MOCs or PSSRs.
The sad part about this is that if you’re getting dinged for having an MOC for a project from 2 years ago, it’s because you were trying to do the right thing. You wanted to make sure every item from the project got taken care of before the MOC was filed away. Ironically, a facility which failed to initiate an MOC for a change to their process might get away with it scot-free because the inspector isn’t savvy enough to identify the lack of an MOC.
So rather than shooting yourself in the foot for doing the right thing, here is what you need to do. Extract the remaining action items from that MOC and relocate them elsewhere to be tracked to completion. Then, simply close out the MOC.
Let’s say you replaced an evaporative condenser, but you still need to (1) paint the piping, (2) label the pipes, (3) install a component marker, and (4) calculate a new energy balance. In this scenario, the condenser has already been passivated and been in service for 18 months, but not all the loose ends have been tied up. In this case, simply move those action items to your master action item tracking list (spreadsheet, PSM software, etc.) and close out the MOC with this note: “The evaporative condenser has been replaced and the PSM program has been substantially updated. The remaining items (painting, labeling, and a new energy balance) will be tracked to completion through the PSM Master Action Item Tracker.”
Then, when the inspector asks to see your open MOCs, you won’t have any! And if they review the completed MOCs, they will likely only check to see they have been properly closed out. And if they dig far enough to ask if there are any remaining action items, you can show them the current status and indicate they are being tracked to completion.
I hope this simple trick will help you in your next audit!
Contact us if you want help implementing your MOCs and PSSRs.
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