[This blog series derives from a technical paper written by Eli Macha, President of Macha PSM]
While Management of Change (MOC) and Pre-Startup Safety Review (PSSR) are two distinct elements, they are often completed in conjunction. For this reason, this blog will treat both elements in one section. A MOC is triggered by, “changes (except for ‘replacements in kind’) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.”[1] PSSRs, on the other hand, must be initiated for, “new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.”[2]
The first—and most obvious—error to correct as it pertains to MOCs and PSSRs is failing to do them at all. If a regulator comes onsite and sees that your facility had a substantial expansion two years ago (for example, 2 new compressors, 1 new evaporative condenser, and 8 new evaporators), they will expect to see corresponding MOC and PSSR documentation. While the productivity of retroactively performing a MOC or PSSR is questionable, the first priority of the PSM Coordinator must be to resolve their team to initiate MOCs and PSSRs for all necessary changes going forward.
This requires three ingredients:
a means
a map
motivation
In order to initiate and complete MOCs and PSSRs, your facility must first have a means to do so. This means you must either obtain or develop MOC/PSSR checklists. This can be done in paper copy, in editable documents, or online through a software. PSM-specific software will obviously have MOC and PSSR checklists, but other software types can usually be modified to include such checklists.
Secondly, the employees at your facility need a map for how to complete MOCs and PSSRs. If you are the only one at your facility who knows how to initiate, fill out, and complete the MOC/PSSRs, then, not uncoincidentally, you will be the only person initiating, filling out, and completing MOC/PSSRs. You need to train your employees and management on how and why to initiate MOC/PSSRs.
Lastly, your team needs motivation. If you are the only team member who cares about MOC/PSSRs, your process is doomed to fail. A quality PSM software will send emails or other notifications to responsible parties that they have MOC/PSSR tasks to complete. If there is no automation setting, the PSM Coordinator will need to take a more active role in staying on top of MOC/PSSRs. One past client of the author took advantage of peer pressure for MOC/PSSR motivation. They had a whiteboard where they would list where each MOC was in the process and who was responsible for moving it to the next step. While the method may be harsh, its results spoke for itself.
After the PSM Coordinator has achieved the goal of having their team properly initiate the necessary MOCs and PSSRs, the low-hanging fruit is to get them to close out these records promptly. A commonly held belief in the ammonia refrigeration industry is that MOCs and PSSRs must remain “open” until all corresponding action items have been closed. Contrary to what many assume, the PSM and RMP regulations are devoid of any such verbiage. If an MOC is still open for a project that was completed three months ago, simply move the action items to a separate list and then close out the MOC. Indicate in the closed MOC where the recommendations will be tracked to completion. Regulators want to see that MOC/PSSRs are being properly initiated and completed. If they find that your facility is still tracking a couple of loose ends a few months after the fact, but the MOC and PSSR were properly closed, it is doubtful they will penalize the facility.
Finally, how does one take their MOC and PSSR implementation to the next level in the ammonia refrigeration industry? The first and best way to do this is to update the PSSR checklists to align with IIAR standards. For new equipment and systems, the PSSR checklist should be catered to ANSI/IIAR 5-2019 American National Standard for Startup of Closed-Circuit Ammonia Refrigeration Systems. For decommissioning of new equipment and systems, the PSSR checklist should be catered to ANSI/IIAR 8-2020 American National Standard for Decommissioning of Closed-Circuit Ammonia Refrigeration Systems.
In addition to customizing your PSSR checklists, it would be helpful to customize your MOC checklist. Most MOC checklists ask if process safety information (PSI) needs to be updated. Unless you are an experienced PSM practitioner and know the facility’s PSI frontward and backward, it will be difficult to easily determine which PSI sub-elements will need to be updated (e.g., safe operating limits, P&IDs, relief system design and design basis). Furthermore, it may be beneficial to ask for specific documents such as manufacturer data reports and pipe mill certificates.
[1] Title 29 CFR §1910.119(l)(1) & Title 40 CFR §68.75(a)
[2] Title 29 CFR §1910.119(i)(1) & Title 40 CFR §68.77(a)
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