The ancient Greek philosopher Heraclitus is credited with saying, "The only constant is change." This certainly proves true in the process safety management world. Management of changes (MOCs) can be quite intimidating and tedious to those unfamiliar with the process. But a failure to implement of MOCs will the rest of the 14 elements of PSM in shambles, not to mention, the safety of the system becoming compromised.
Here is a summary of the management of change requirements found in Title 40 CFR §68.75 and Title 29 CFR §1910.119(l):
Facilities are required to establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures, as well as changes to the facility that affect a covered process. These procedures must address considerations such as the technical basis for the proposed change, its impact on safety and health, modifications to operating procedures, necessary time period for the change, and authorization requirements. Employees involved in operating a process and maintenance and contract employees affected by the change must be informed of and trained in the change before start-up. If the change results in a change in the process safety information or operating procedures, the relevant information or procedures must be updated accordingly.
If you're looking for help initiating or overseeing an MOC, submit a request through our contact page.
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