| What the regulation says:
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(l)(1) 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.
(l)(2) The
procedures shall assure that the following
considerations are addressed prior to any
change:
(l)(2)(i) The
technical basis for the proposed change;
(l)(2)(ii) Impact
of change on safety and health;
(l)(2)(iii) Modifications
to operating procedures;
(l)(2)(iv) Necessary
time period for the change; and,
(l)(2)(v) Authorization
requirements for the proposed change.
(l)(3) Employees
involved in operating a process and maintenance
and contract employees whose job tasks will be
affected by a change in the process shall be
informed of, and trained in, the change prior to
start-up of the process or affected part of the
process.
(l)(4) If
a change covered by this paragraph results in a
change in the process safety information
required by paragraph (d) of this section, such
information shall be updated accordingly.
(l)(5) If
a change covered by this paragraph results in a
change in the operating procedures or practices
required by paragraph (f) of this section, such
procedures or practices shall be updated
accordingly.
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| What it means:
| To
properly manage changes to process chemicals,
technology, equipment and facilities, one must define
what is meant by change. In this process safety
management standard, change includes all modifications
to equipment, procedures, raw materials and processing
conditions other than "replacement in kind."
These changes need to be properly managed by identifying
and reviewing them prior to implementation of the
change. For example, the operating procedures contain
the operating parameters (pressure limits, temperature
ranges, flow rates, etc.) and the importance of
operating within these limits. While the operator must
have the flexibility to maintain safe operation within
the established parameters, any operation outside of
these parameters requires review and approval by a
written management of change procedure.
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| Management
of change covers such as changes in process technology
and changes to equipment and instrumentation. Changes in
process technology can result from changes in production
rates, experimentation, equipment
unavailability, new equipment and changes in operating conditions
to improve yield or quality. Equipment changes include
among others change in materials of construction,
equipment specifications, piping pre-arrangements,
experimental equipment, computer program revisions and
changes in alarms and interlocks. Employers need to
establish means and methods to detect both technical
changes and mechanical changes.
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| Temporary
changes have caused a number of catastrophes over the
years, and employers need to establish ways to detect
temporary changes as well as those that are permanent.
It is important that a time limit for temporary changes
be established and monitored since, without control,
these changes may tend to become permanent. Temporary
changes are subject to the management of change
provisions. In addition, the management of change
procedures are used to insure that the equipment and
procedures are returned to their original or designed
conditions at the end of the temporary change. Proper
documentation and review of these changes is invaluable
in assuring that the safety and health considerations
are being incorporated into the operating procedures and
the process.
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| Employers
should develop a form or clearance sheet to
facilitate the processing of changes through the
management of change procedures. A typical change form
should include a description and the purpose of the change,
the technical basis for the change, safety and health
considerations, documentation of changes for the
operating procedures, maintenance procedures, inspection
and testing, P&ID’s, electrical classification,
training and communications, pre-startup inspection,
duration if a temporary change, approvals and
authorization. Where the impact of the change is minor
and well understood, a check list reviewed by an
authorized person with proper communication to others
who are affected may be sufficient. However, for a more
complex or significant design change, a Process Hazard
Analysis should be performed. Changes in documents such as P&IDs,
operating procedures, mechanical integrity programs,
electrical classifications, etc., need to be noted so
that these revisions can be made permanent when the
drawings and procedure manuals are updated. Copies of
process changes need to be kept in an accessible
location to ensure that design changes are available to
operating personnel as well as to PHA team members when
a PHA is being done or one is being updated.
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| Non-routine
work which is conducted in process areas needs to be
controlled by the employer in a consistent manner. The
hazards identified involving the work that is to be
accomplished must be communicated to those doing the
work, but also to those operating personnel whose work
could affect the safety of the process. A work
authorization notice or permit must have a procedure
that describes the steps the maintenance supervisor,
contractor representative or other person needs to
follow to obtain the necessary clearance to get the job
started. The work authorization procedures need to
reference and coordinate, as applicable, lockout/tagout
procedures, line breaking procedures, confined space
entry procedures and hot work authorizations. This
procedure also needs to provide clear steps to follow
once the job is completed in order to provide closure
for those that need to know the job is now completed and
equipment can be returned to norma |
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