MANAGEMENT
OF CHANGE

A key element of OSHA Process Safety Management (PSM) is the requirement for, and adherence to, a Management of Change (MOC) procedure.

Before change Implementation:  

• document the technical basis for change 
• assess the impact of the change
• acquire proper approvals 

After change Implementation: 

• mechanical integrity inspections 
• pre-startup safety review 
• conduct training
• update process safety information

The OSHA Process Safety Management (PSM) regulation requires a Management of Change (MOC) procedure to be initiated for asset changes (process chemicals, technology of the process, equipment and facilities) as well as procedures. Furthermore, there is an evolving consensus that organizational changes are also changes that should be managed by MOC. The exception is when the change is a Replacement in Kind (RIK).

“Replacement in Kind” (RIK) in the context of OSHA’s Process Safety Management (PSM) regulation, allows certain replacements that meet original design specifications to bypass the formal Management of Change (MOC) process. 

There are three primary assumptions that guide Replacement in Kind (RIK) decisions. 

• “Grandfathering” allows identical part replacements
• “Generic” permits parts from alternative manufacturers with the same operational criteria 
• “Recognized and Generally Accepted Good Engineering Practices” (RAGAGEP) 

• A Management of Change (MOC) procedure must accommodate a wide range of potential changes from low to high complexity, cost or risk  
• Management of Change (MOC) requires rigorous document management controls for each Management of Change (MOC) project
• A Management of Change (MOC) project typically involves different participants, skills, authority, etc. to accomplish