In this episode, Molly and John discuss the subtleties of Management of Change (MOC). If you're familiar with MOC, then you already know that in order to comply with the PSM standard, you need to "establish and implement written procedures to manage changes (except for 'replacements in kind') to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process". But what if the line between a real change and a replacement in kind isn't totally clear? For example, what if you replace a pressure relief device with another of the same size, but the replacement is from a different manufacturer than the original device? Tune in to this episode to learn more about this specific situation and other similar cases, where you might find yourself on the fence about whether an MOC is truly required. 


Have a specific scenario that we didn't discuss? Send an email to [email protected] and our consultants will respond with their expert advice. 


For those not familiar with MOCs, we suggest checking out these previous episodes of our show:


Episode 5 - MOC & PSSR


PSM: Back to Basics, Part 4 - Management of Change (MOC)


Episode 48 - Management of Organizational Change (MOOC)