CSB’s Recommendations on PSM Standard and Management of Change

The U.S. Chemical Safety Board (CSB) took quite a stand recently against OSHA, criticizing the federal agency for failing to implement several key recommendations they have made over the last decade. At the public meeting held last month on July 25 in Washington, the CSB officially deemed OSHA’s response “unacceptable.” One of the seven long-standing recommendations that was up for discussion concerns a revision to the process safety management (PSM) standard, specifically the section that refers to management of change: 29 CFR 1910.119(1).

The CSB’s Recommendation
The official recommendation, made over six years ago on March 20, 2007, reads as follows:

Amend the OSHA PSM standard to require that a management of change (MOC) review be conducted for organizational changes that may impact process safety including:

a) Major organizational changes such as mergers, acquisitions, or reorganizations;
b) Personnel changes, including changes in staffing levels or staff experience; and
c) Policy changes, such as budget cutting.

This recommendation was issued after a 2005 refinery accident in Texas City killed 15 people and injured an additional 180 workers. The direct cause of the accident was attributed to hydrocarbon vapors that flooded a distillation tower and combusted after coming into contact with an ignition source.

However, there were several contributing causes identified that related to a lack of corporate oversight and a defective change management process. One report stated that “many changes in a complex organization had led to the lack of clear accountability and poor communication.”

The CSB independently concluded that poorly managed corporate mergers, leadership and organizational changes, and budget cuts had all contributed to an increased risk of catastrophic accidents at the site. The CSB also cited a 2002 survey which revealed only 44% of chemical processing companies assess organizational change in their MOC programs.

OSHA’s Response
Despite these conclusions, OSHA deemed the amendment unnecessary. OSHA believes that the current standard adequately addresses the management of organizational changes; the CSB does not agree.

“Over the years, the CSB has made a number of recommendations to OSHA in the aftermath of tragic accidents that have killed dozens of workers, injured hundreds more, and cause millions of dollars in property damage,” says CSB Chairperson Rafael Moure-Eraso, speaking out about the decision. “Yet insufficient progress has been made.”

With the status of this recommendation now listed as “Open – Unacceptable Response,” it’s still unclear if we’ll ever see this suggestion officially implemented. However, given the imprecise wording of OSHA’s current section on PSM and management of change, it’s not hard to support further clarification within the standard itself.

Intelex and Management of Change
Intelex’s new Management of Change application can be used for both organizational and operational change. Regardless of whether your change affects a “covered process” as per OSHA’s PSM definition, or whether change management is regulated at all within your industry, we strongly believe that managing change through a controlled process is a key aspect of risk management.

A carefully thought out change management plan leads to safer workplaces, increased user adoption and ultimately a more successful change implementation.

Management of Change Resources

  • Review the CSB’s recommendation yourself here
  • Review OSHA’s Process Safety Management of Highly Hazardous Chemicals standard here
  • To learn more about Intelex’s Management of Change application, Request a Free Trial or speak to someone directly by calling us at 416-599-6009
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About Alison Grenkie

In my role as an Intelex Product Marketing Manager I get to write about all things EHS and Quality. I'm particularly passionate about safety and sustainability in the resources and energy sectors, including oil and gas, electricity generation and distribution, mining and more. I love sharing ideas, best practices and other insights that can help companies boost their bottom lines while building a better world.

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