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Tag Archives: Management of Change
Is a condenser change a Replacement in Kind?
The Question: Imagine a project where you are going to replace an existing condenser with a newer model. Does this “change” trigger the MOC element or does it fall into the Replacement in Kind exemption to the MOC requirement? This … Continue reading
Posted in Compliance, EPA, IIAR, Management of Change, OSHA
Tagged EPA, Management of Change, OSHA, PSM, RAGAGEP, RMP
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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
Posted in Compliance, Management of Change, System Optimization
Tagged Management of Change, PSM, RMP
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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
Posted in Compliance, EPA, Good Engineering Practices, Management of Change, OSHA
Tagged EPA, Management of Change, OSHA, PSM, RMP
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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
Posted in Compliance, Good Engineering Practices, Management of Change
Tagged EPA, Management of Change, OSHA
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