Category Archives: Management of Change

RAGAGEP Hierarchy in Application – A worked example

RAGAGEP (Recognized and Generally Accepted Good Engineering Practices/Principles) is extremely important to our Process Safety programs as it helps define the boundaries of what is (and isn’t) acceptable in our processes and our management of them. There seems to be … Continue reading

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Management Of Change (MOC) for Personnel

In response to a recent LinkedIn forum post, here’s a short discussion on why MOC should be implemented for some personnel changes. 1910.119(l)(1) The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to … Continue reading

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Why does my PSM program make me review the PHA during any equipment/facility MOC?

Nearly two years ago, I changed the Management of Change Written Plan template in my PSM programs to make a few changes: Removed the “minor change” and “major change” categories. Explicitly require a Process Hazard Analysis review during all equipment/facility … Continue reading

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Misunderstanding MOC

Recently a valve manufacturer that I respect posted a LinkedIn advertisement for one of their new relief valves. I love new technology so I was really interested in it but noticed something they posted in the graphic: “No PSM Changes … Continue reading

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Here’s a change that doesn’t require a Formal MOC!

I am sure many of my PSM friends have noticed my lethargic posting rate at the blog over the past year or so. I’ve been running all around the country helping people with their PSM programs through Audits, PHA’s and … Continue reading

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A debate on Management of Change

Recently a group of safety yahoos got together to discuss a situation: You have a freezer with racking. The racking needs to be removed for XXXX reason. You hire a contractor to do the job. You evaluate and train the … Continue reading

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OSHA cites Kraft in Madison Wisconsin

MADISON, Wis. – The U.S. Department of Labor’s Occupational Safety and Health Administration has cited Kraft Foods Inc. for 12 serious and one other-than-serious safety violation at a facility of its subsidiary, Oscar Meyer, in Madison. Proposed fines total $75,000. … Continue reading

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