This document examines what a change is in the context of the OSHA PSM regulation, which specifically lists 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. And finally, the notion of impacts of systemic change is introduced.
MOC almost always requires changes to process safety information. A thorough review of PSI is presented, within the practical limitation that it’s impossible to know what every company calls every kind of document.
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