Training Management of Change Approvers

Many companies have made great strides in change management systems since OSHA's Process Safety Management Standard 29 CFR 1910.119 was first promulgated in 1992. This standard required “implementation of written procedures to manage changes… that affect a covered process”i. Although significant improvements have been made, there is one area of change management that is often overlooked. Changes in personnel such as staffing levels, work hours and reassigned job responsibilities are frequently either not covered or are covered inadequately by existing change management systems. This paper addresses one element of personnel change by reviewing a system in use at Dow Chemical Company for conducting 2nd level MOC approver endorsement reviews for new production managers. Key questions answered will include: who should attend the review, what are the minimum expectations of a new production manager and why is this review so critical to process safety. iProcess Safety of Highly Hazardous Chemicals (29 CFR 1910.119), U.S. Occupational Safety and Health Administration, May 1992, available at www.osha.gov.