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