In this third installment of our series on “Lessons Learned” in the last ten years of the Petroleum Refinery Process Safety Management National Emphasis Program (NEP), I would like to talk about the Management of Change (MOC) requirement of the PSM standard.
In fact, while this series has focused on Petroleum Refineries, MOC is really something that all employers should be thinking about, even those not covered by the PSM-standard. While I have spent much of my career as a safety lawyer counseling clients on how to avoid OSHA citations, my primary reason for urging companies to have a robust MOC program is that most serious accidents that I have seen usually involved some failure to manage change.
So how do companies get into trouble? Too often, companies fail to follow their MOC process because they believe the change is minor and, on the surface, appears to be an improvement, such as installing a control valve bypass, implementing a minor procedure for installing a new type of relief device, or changing the inspection intervals for a piping circuit. What could go wrong?
But there are good reasons why companies should have and follow MOC procedures. MOC procedures ensure that certain issues are considered before adopting any changes, such as the technical basis justifying the proposed change, the impact of the change on safety and health, the modifications to operating procedures, the necessary time period for the change, and the authorization requirements for the change. It is also essential that employees who will be affected by any change are informed of, and receive training on, the change prior to its implementation.
Finally, don’t forget that MOC procedures should also be followed when making temporary changes, and should specifically address the amount of time that the temporary change will be operative. It’s not simply about avoiding citations; MOC procedures save lives too.