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 required.” When we are replacing one valve for another and that valve is not an IDENTICAL replacement, this is VERY wrong.

Work through this with me here…

Changing a relief valve to a different type of valve would still require you to evaluate:

  • PHA: Does your PHA anticipate/support the use of this valve? It’s definitely classified as an engineering control (119(e)(3)(iii)) that needs to be part of your PHA.
  • PSI: Does it have the same capacity? Are your relief calculations still accurate?
  • MI/SOP: Is it maintained, inspected, installed and replaced the same way (1910.119(j)(2-5))?
  • Training: Are your people trained to maintain, inspect, install and replace it? (1910.119(j)(5))
  • PSSR: This definitely requires updated PSI (119(i)(1)), so not only does it require an MOC (1910.119(l)(4-5)) it requires a PSSR as well to ensure that the equipment is installed correctly and that:
    • Safety, operating, maintenance, and emergency procedures are in place and are adequate (119(i)(2)(ii))
    • Training of each employee involved in operating a process has been completed. (119(i)(2)(iv))

PHA: This is actually the element that should drive you to look at every other part of your PSM program mentioned here. In your PHA, you likely take credit for an engineered relief calculation (PSI element), a Maintenance Program (MI Element) including written procedures (MI & possibly SOP elements) and Training (Training element)

PSI: Let’s assume you check and it does have the same capacity: Don’t you want to take credit for this work and document it? I’ve never seen a relief calculation that didn’t show the relief valve model so won’t you want to update that as well? Do you have the new cut-sheet in your PSI IOM binder(s) and have you made your people familiar with it?

MI/SOP: Does the current MI schedule work for the new valve? Do the current maintenance, inspection, installation and replacement procedures work for the new valve? Again, even if they do, don’t you want to document that you looked?

Training: Have you conducted training on any differences you found in the elements above?

PSSR: Have you documented a PSSR that shows that the program has been updated, an MOC conducted (and closed out), written procedures provided and that training has been completed?

I am guessing they are trying to call this a Replacement in Kind but that is pretty sloppy thinking even if it were still the 90’s. Let me remind you of my favorite MOC guidance from the old OSHA PSM directive:

The standard requires that an MOC procedure be completed, regardless of whether any safety and health impacts will actually be realized by the change. The intent is, in part, to have the employer analyze any potential safety and health impacts of a change prior to its implementation. Even if the employer rightly concludes there would be no safety and health impacts related to a change, 1910.119(l)(1) still requires the employer to conduct the MOC procedure. The MOC requirements are important because many large incidents have occurred in the past when changes have been made and the employer either did not consider the safety and health impacts of the change, or did not appreciate (wrongly concluded) the potential consequences of the change before it was too late. Therefore, it is not only required, but important that the employer conducts an MOC procedure on each change, even those changes the employer believes will have no safety or health impacts.

About Brian Chapin

PSM / RMP Compliance Consultant
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