Management of Change Requirements

In the United States, refrigeration systems that are subject to OSHA’s Process Safety Management (PSM) standard (29 CFR 1910.119) and/or to EPA’s Risk Management Plan (RMP) regulation (40 CFR Part 68) are required to follow Management of Change requirements to manage changes to process chemicals, technology, equipment, and procedures.

COVID19 may temporarily affect how facilities comply with PSM and RMP requirements. For example, due to social distancing limitations facilities may be forced to:

  1. Delay and/or modify training activities
  2. Delay and/or modify tests and inspections
  3. Minimize on-site activities during PSM/RMP compliance audits
  4. Minimize employee participation during PHA studies and PSM/RMP compliance audits.
Make sure that Management of Change requirements are followed to document any temporary changes made to the PSM/RMP program to address COVID19 limitations. As always, proper documentation is essential for compliance with the regulations