This document discusses the criteria and regulatory requirements for determining when a Management of Change (MOC) is necessary, as mandated by OSHA’s Process Safety Management (PSM) standards (1910.119).
An MOC is required if a proposed activity within a covered process constitutes a change that is not simply a replacement-in-kind. Understanding whether a process is “covered” is essential, as processes that do not fall under PSM regulations avoid associated compliance costs. Covered processes involve either specified quantities of hazardous chemicals or significant quantities of flammable substances, with exemptions for retail, oil, gas, and remote facilities.
The document examines key terms, including “process,” which encompasses any activity involving hazardous chemicals. The PSM standard applies broadly to interconnected and closely located components that could contribute to or exacerbate a hazardous chemical release. OSHA interpretations clarify ambiguities in applying PSM to specific cases, such as differentiating between manufacturing and using explosive devices.
Legal interpretations have further refined PSM applications, with a focus on OSHA’s intent to prioritize safety over semantic distinctions, underscoring the importance of correctly defining covered processes for effective safety management.
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