Management of change (MOC) is a commonly used technique. Its purpose is to:
• Identify the potential consequences of a change.
• Plan ahead so that counter actions can be taken before a change occurs and continuously as the change progresses.
With respect to operational risks, the process ensures that:
•Hazards are identified and analyzed, and risks are assessed.
•Appropriate avoidance, elimination or control decisions are made so that acceptable risk levels are achieved and maintained throughout the change process.
•New hazards are not knowingly introduced by the change.
•The change does not negatively affect previously resolved hazards.
•The change does not increase the severity potential of an existing hazard. This process is applied when a site modifies technology, equipment, facilities, work practices and procedures, design specifications, raw materials, organizational or staffing situations, and standards or regulations. An MOC process must consider:
•safety of employees making the changes;
•safety of employees in adjacent work areas:
•safety of employees who will be engaged in operations after changes are made;
• public safety:
• product safety and quality:
•fire protection so as to avoid property damage and business interruption.
OSHA's (1992) Process Safety Management Standard (29 CFR 1910.119) requires that covered operations have an MOC process in place. No other OSHA. regulation contains similar requirements, although the agency does address MOC in an information paper (OSHA, 1994). Also, this subject is a requirement to achieve designation in OSHA's Voluntary Protection Programs.
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