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PT Notes

OSHA RFI - Expanding the Scope of Mechanical Integrity and Management of Change Requirements

PT Notes is a series of topical technical notes provided periodically by Primatech for your benefit. Please feel free to provide feedback.

On December 3, 2013, the U.S. Occupational Safety and Health Administration (OSHA) announced a request for information (RFI) seeking public comment on potential revisions to its Process Safety Management (PSM) standard. Multiple issues were addressed in the RFI.

One issue deals with expanding the scope of the Mechanical Integrity (MI) requirements to any safety‑critical equipment. The PSM standard states that the requirements apply to pressure vessels and storage tanks, piping systems (including piping components such as valves), relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. In the preamble to the final rule, OSHA explained that if an employer deems additional equipment to be critical to a particular process, the employer should consider that equipment to be covered by the standard and treat it accordingly.

In light of the limited list of covered equipment provided in the standard, OSHA addresses hazards associated with other types of safety‑critical equipment through citations for violations of the General Duty Clause of the Occupational Safety and Health Act. OSHA believes that revising the PSM standard to apply the MI requirements explicitly to all equipment that the employer identifies as critical to process safety, in addition to the equipment currently listed in the standard, would provide industry with proper notice regarding coverage of such equipment.

OSHA has posed these questions on this issue in the RFI:

  1. Does your facility have any equipment not covered under the MI requirements of the PSM standard that is critical to process safety? If so, what type(s) of equipment? Did you identify the equipment as safety‑critical through a process hazard analysis? How did your facility determine that the equipment was safety‑critical, and does your facility treat the equipment as if it were PSM-covered for safety or other reasons?
  2. Please provide any data or information on workplace accidents, near misses, or other safety‑related incidents related to the mechanical integrity of safety‑critical equipment not covered under the standard.
  3. Would expanding the scope of the MI requirements to cover the mechanical integrity of all equipment the employer identifies as critical to process safety, in addition to the equipment currently listed in the standard, prevent worker injuries and fatalities?
  4. What would be the economic impact of expanding the scope of the standard in this way? Are there any special circumstances involving small entities that OSHA should consider with respect to this option?

Another issue deals with clarifying Management of Change (MOC) requirements with an explicit requirement that employers manage organizational changes. The existing standard does not explicitly state that employers must follow management‑of‑change procedures for organizational changes, such as changes in management structure, budget cuts, or personnel changes. However, it is OSHA's position that the current MOC requirements cover organizational changes if the changes have the potential to affect process safety. Since the promulgation of the PSM standard, it has become well recognized that organizational changes can have a profound impact on worker safety and, therefore, employers should evaluate organizational change like any other change.

OSHA has posed these questions on this issue in the RFI:

  1. What do you consider to be an organizational change within the context of PSM practices? For example, would you consider the following, or similar, changes to be organizational changes: reducing the number of operators in a shift; changing from 5‑day to 7‑day operations; changing from 8‑hour to 12‑hour operator shifts; replacing a unit manager; relocating a technical group to a remote corporate location; or changing a supervisory or compensation structure?
  2. If your facility has established and implemented written procedures for management of organizational changes, please describe any economic impacts associated with the procedures.
  3. Would clarifying the MOC requirements with an explicit requirement that employers manage organizational changes prevent worker injuries and fatalities? What would be the economic impact of such a clarification? Are there any special circumstances involving small entities that OSHA should consider with respect to this option?
  4. Please describe any organizational changes made in your facility or organization that have had the potential to affect process operations. Were management‑of‑change procedures followed before making the changes?
  5. What do you consider to be the best safety practices concerning management of organizational change?
  6. Please provide any data or information on workplace accidents, near misses, or other safety‑related incidents involving the failure to manage organizational change. Would following current management‑of‑change procedures in the PSM standard prevent these incidents?

For more information, you can contact Primatech or click on this link:

Federal Register notice

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