Management of Change - hdbk11010095

DOE-HDBK-1101-96

2.10 Management of Change

29 CFR 1910.119 (l)

(1)

The employer shall establish and implement written procedures to manage changes (except for "replace-

ments in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that

affect a covered process.

(2)

The procedures shall assure that the following considerations are addressed prior to any change:

(i)

The technical basis for the proposed change;

(ii)

Impact of change on safety and health;

(iii)

Modifications to operating procedures;

(iv)

Necessary time period for the change; and,

(v)

Authorization requirements for the proposed change.

(3)

Employees involved in operating a process and maintenance and contract employees whose job tasks will be

affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the

process or affected part of the process.

(4)

If a change covered by this paragraph results in a change in the process safety information required by

paragraph (d), such information shall be updated accordingly.

(5)

If a change covered by this paragraph results in a change in the operating procedures or practices required

by paragraph (f), such procedures or practices shall be updated accordingly.

Intent

The intent of the MOC element is to require management of all modifications to equipment,

procedures, materials, and processing conditions other than replacement in kind. All changes should

be identified and reviewed prior to their implementation, and the impact of design, operational, and

procedural changes on process safety should be addressed and managed. A process change is

defined as any alteration, whether temporary or permanent, that could affect the control or integrity

of a system covered by the PSM Rule. This element is a critical part of the PSM Rule because it

helps to integrate many of the other elements of the Rule. Process changes include:

changes in process technology such as raw materials, process chemistry, process control

systems, equipment design, and piping and equipment specifications;

addition or removal of process equipment or piping;

changes in process parameters;

changes in utilities;

changes in procedures;

changes in facilities; and

personnel changes (OSHA has held that personnel changes are inferred in term facilities).

Corresponding DOE Programs and Requirements

Management of change is addressed under DOE 5480.19,CONDUCT OF OPERATIONS

REQUIREMENTS, and DOE O 424.1, UNREVIEWED SAFETY QUESTIONS. Programs that

address configuration control also support this element. For new construction, configuration control