In response to a recent LinkedIn forum post, here’s a short discussion on why MOC should be implemented for some personnel changes.
The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
Certainly, a change to certain personnel can be a change that affects a covered process and OSHA has cited this before when key players have changed such as the PSM coordinator, Maintenance Manager or Safety Director.
To make life simpler, I use the “Management System” rule of thumb. If the person is listed as a “Responsible Person” in the RMP Management System then they are covered in the MOC procedure.
Here are my MOC/PSSR Written Plan (a.k.a. Guideline) section for MOC regarding personnel.
Note that Operators that have no other role in the Management System are not covered under this procedure as they are already covered in the Training element. Here is the form the above procedure is referencing:
Every program I’ve written and PSM class I’ve taught over the last five years uses some variation of this procedure/form.
