83. What documentation is needed to demonstrate compliance with MOC requirements?
Other than having a written MOC procedure, no specific documentation is required for MOC
beyond updating existing PSI and operating and maintenance procedures. However, many
process safety experts agree that having a request for change form is necessary to document
changes. These forms should contain enough information to ascertain that all considerations
required under the PSM Rule for each change have been resolved.
84. What type of review method must be used to evaluate the impacts of changes on safety
and health? How many people must review each change situation?
DOE contractors may use a graded approach to develop the review method and authorization
procedure appropriate for each class of change in a covered process. The level of review should
be commensurate with the potential risk associated with the change. DOE contractors should
consider the degree to which the change introduces new potential hazards or affects
safety-critical systems or components.
85. Are any types of changes on or around a covered process (e.g., changes to safety
showers, catwalks, structural steel) intended to be excluded from MOC requirements?
DOE contractors should decide what types of facility changes, excluding replacement-in-kind, to
cover under the MOC system. Contractors should use caution in simply dismissing any broadly
defined class of change because no apparent safety and health impacts can be seen on a generic
86. What does necessary time period for change mean?
Used in conjunction with temporary changes, it means the time that the change is allowed to
exist without undergoing further review.