Managing Process Changes: Who's Reacting - Your Chemicals Or You?

For more information, contact Elena Rivera at 512.329.5544. 

Taking a reactionary position, rather than proactively managing changes related to process chemicals, may result in a facility incident and possibly an OSHA fine. OSHA's Process Safety Management (PSM) standard and EPA's Risk Management Plan (RMP) require that facilities manage changes to their process chemicals and associated technology, equipment, and personnel. OSHA's PSM standard and EPA's RMP rule both require ongoing documented management of changes, pre-startup reviews prior to introducing chemicals to new or modified facilities, and regular internal PSM/RMP compliance audits.

Even though the OSHA Process Safety Management (PSM) standard has been in effect since 1992, and the EPA Risk Management Program (RMP) rule since 1996, facilities continue to receive hefty fines and citations following agency inspections or audits. A review of a sampling of OSHA news releases issued between 1995 and 2001, indicated fines ranging from $64,000 to $2.5 million for violations of the OSHA PSM standard, the General Duty Clause, and other related regulations.

In August of this year, the U.S. Chemical Safety and Hazard Investigation Board (CSB) issued a safety bulletin (No. 200104-SB) highlighting the role that Management of Change (MOC), or rather the lack thereof, played in incidents which resulted in deaths, illnesses, and property damage at two large chemical facilities. MOC should be tailored for each facility and requires that facilities manage changes to their process chemicals and associated technology, equipment, and personnel. MOC is required by both the OSHA PSM standard, codified as Title 29 of the Code of Federal Regulations, Section 1910.119 (29 CFR 1910.119), and the EPA RMP rule, 40 CFR Part 68.

Note: In the remainder of this article I will refer only to OSHA's PSM standard, but keep in mind that the same requirements apply under the "Prevention Program" component of EPA's RMP rule.

STEP 1 - WHAT CONSTITUTES A "CHANGE" UNDER MOC? The first step in managing changes in process chemicals, technology, equipment, or related personnel or procedures, is to clearly define what constitutes a "change" that needs to be managed. Changes under the MOC element of the PSM standard include changes to raw materials; processing parameters such as temperatures, pressures, or flows; technology; equipment; operating or operations management personnel; and facilities. "Replacement in kind" changes are excluded. The classic example of a "replacement in kind' change is a pump that is changed out for another pump that meets the same design specifications.

Changing the operating parameter ranges established in the operating procedure or processing instructions will require changes to the operating procedures, process diagrams, and/or training. If an operator has been trained on operating within the established operating parameters, operating outside these ranges must have MOC review, documentation, and approval. And the operator must now be trained on the conditions and new potential upsets that could result.

Examples of changes in process technology include changes in raw materials, catalysts, or production rates; experimental runs; the use of different equipment while the original equipment is being serviced; or new equipment or instrumentation.