PSM and Petroleum Refineries: Lessons Learned (Part 3)
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
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.