Management of Change: When Is It Regulated?

“If you want to truly understand something, try to change it.”  — Kurt Lewin

All change should be managed; in any endeavor, under any circumstances. When people ask about management of change, however, they are usually talking about the specific regulatory requirements of the Occupational Safety and Health Administration (OSHA) and its Process Safety Management (PSM) standard or the regulatory requirements of the United States Environmental Protection Agency (EPA) and its Risk Management Planning (RMP) rule.

Because those federal agencies are very specific in their extensive requirements for Management of Change (MoC, as opposed to MOC, which many reserve for “Materials of Construction”), there is a lot of interest in knowing when the required documentation of MoC is needed.

It is not always clear, so the issue can be contentious.

When Is Change Not Regulated by PSM or RMP?

There are two instances when the process safety regulations do not require executing an MoC procedure. The obvious case is when the change is not in a process covered by either of the regulations. The second case, which is not quite so obvious, is when the change is a “replacement in kind.” Changing a component with an identical component—for instance, replacing a part with a part that has the same part number—is a replacement in kind. So is replacing a component with a component that meets the specification for the component being replaced, even if the new component is a different make and model. Sometimes, though, it is a challenge to decide whether a change is in fact a “replacement in kind”.

When Is Management of Change Required by the Regulations

Both OSHA and the EPA require MoC procedures for changes to

• Process chemicals
• Technology
• Equipment
• Procedures

These are the categories for which the regulations make an exception for “replacements in kind,” that is, any replacement that “satisfies the design specification.”

The more specific the design specification, the more likely it is that a replacement will not be a replacement in kind. If the specification is for 50% caustic, a commodity chemical, it does not require an MoC to switch vendors. It would require an MoC to switch to 20% caustic. If the specification is for a certain specialty chemical, where the presence of trace impurities may influence how it performs, it is more likely that an MoC is required to make the switch.

It’s hard to imagine a change in technology that will not require an MoC. Likewise, a change in procedures will probably prompt an MoC. A change in equipment, on the other hand, could very well be a replacement in kind, even with another vendor’s equipment.

For example, an ASME B73.1 (ANSI) centrifugal pump manufactured from the materials of construction allowed for in the specification and with the same flow and pressure characteristics will be a replacement in kind, even if it comes from a different vendor. Replacing the same pump with a gear pump, however, will not be a replacement in kind—unless the specification explicitly says that either centrifugal pumps or gear pumps satisfy the design specification. Likewise, a change in the material of construction of any component, even to a superior material of construction, will require an MoC unless the specification provides for that choice of materials of construction.

Changes to Facilities That Affect a Covered Process

Both regulations list another condition when an MoC is required: “Changes to facilities [stationary sources in RMP] that affect a covered process.” For this condition, there is no exception for replacements in kind.

An example of a change to a facility that would affect a covered process is rerouting the path that trucks take through a covered process to pick up or deliver materials. This could conceivably change the chance of collision or spill and should be addressed by an MoC.

A much less obvious example is addressed in the OSHA memorandum to regional administrators issued on March 31, 2009. It concerns organizational changes. Director Fairfax points out that “some organizational changes, such as changes resulting from mergers, reorganizations, staffing changes, or budget revisions, may affect PSM at the plant level and would therefore trigger a PSM MOC procedure.” The memo then goes on to give two examples:

• Personnel changes, including changes in staffing levels, staff experience, or contracting out that directly impact PSM-covered processes.
• Policy changes, such as budget cutting, that impact PSM-covered processes.

The memo encourages OSHA inspectors to consider issuing a citation when an MoC review has been performed, including of an organizational change, “but necessary safety actions have not been performed in a timely manner to control the hazard.”

What Is in an MoC Review?

Just as a reminder, an MoC review under the PSM standard or the RMP rule has several required elements:

• The technical basis for the proposed changes.
• The impact of the change on safety and health.
• Modifications to operating procedures.
• Necessary time period for the change (when the change goes into effect, and if temporary, when the change is reverted to the original state).
• Authorization requirements for the proposed change.

Employees and contract employees involved in operating or maintaining the process need to be informed of the change before being exposed to it, and all documentation needs to be updated before it goes into effect.

“All That Paperwork”

Admittedly, it would be easier to make a change, either in response to an emergency or to improve operations, if people didn’t have to deal with “all that paperwork.” But that’s not an option. “All that paperwork”—the review and the documentation—can serve to save us from the review and documentation that comes with the incident investigation that has to look into things when a change proves to be ill-considered.

Make MoC Procedures Easy to Use, Then Use Them

Many changes do not require an MoC because many changes are simply replacements in kind. But a lot of changes are more than a replacement in kind; in a covered process, an MoC is absolutely required for these changes. If there is resistance in an organization to perform an MoC, it may be that the problem is not with the organization, but the MoC procedure. Let’s all make sure that our MoC procedures are easy to use and then make sure we are using them when we need to.