ENV-13-52 Examining the Risks of the PSM ‘replacement in kind’

Description:

Under the Process Safety Management (PSM) program, one of the 14 essential elements is the Management of Change (MOC) process. This process is one of the key elements of the PSM program intended to meet the 29 CFR 1910 purpose of “requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosive hazards.” Using the MOC process to address all areas of the facility helps to reduce potential risks. In an effort to reduce paperwork, the MOC process sometimes includes a provision for changes that will not have an impact on the process (i.e. otherwise exempt from the specific requirements under the MOC process). These changes are considered “replacement in kind” and do not make a “change” to the operations of the existing system. These “replacement in kind” are essentially changes that leave the equipment exactly the way it was prior to starting the work.