IRC

May2009

ReplacementinKindvs.ChangetriggeringaMOC
ThePSMStandardrequiresthatfacilitieswithcoveredprocessesmanagechangesthatdirectlyor materiallyaffectthecoveredprocess. 1910.119(l)ManagementofChange (1) Theemployershallestablishandimplementwrittenprocedurestomanagechanges (exceptreplacementinkind)toprocesschemicals,technology,equipment,andprocedures andchangestofacilitiesthataffectacoveredprocess. Oftentimes,thereisconfusionastowhatconstitutesachangevs.areplacementinkindrelatedtothe abovementionedareas:processchemicals,technology,equipment,procedures,andchangesto facilities.ThetablebelowprovidesexamplesofchangesthatwouldrequireaMOCaswellassomethat arereplacementsinkindthatwouldnotnecessitateaMOC.

Case

Description

MOC Required? Yes No

Examples of Process Chemical Changes Lubricant changes in compressors from mineral1 based to semi-synthetic or fully-synthetic oil Acceptance of a shipment of inbound refrigerant2 grade anhydrous ammonia from an alternate supplier Acceptance of a shipment of inbound anhydrous 3 ammonia that is metallurgical grade rather than refrigerant grade The change of a water treatment regimen from a 4 chemical to a non-chemical program Addition of a brine mixing state to a space 5 adjacent but connected to the machinery room The change of secondary fluid type on an 6 ammonia chiller (e.g. from calcium chloride to sodium chloride) Change in salt concentration in a secondary fluid 7 system outside of the normal range The change in product formulation (but of similar 8 composition) being chilled using a scraped surface heat exchanger

IRC

May2009

Case

Description

MOC Required? Yes No

Examples of Technology Changes Conversion of a glycol system to a direct9 refrigerant system Conversion of a direct-refrigerant system to a 10 glycol system 11 Conversion of ceiling-hung to penthouse air units Conversion of an atmospheric pressure relief 12 vent system to an internal relief system Replacement of a 100 ton screw compressor with 13 100 ton reciprocating compressor Examples of Equipment Changes Replacing carbon steel piping with stainless steel 14 tubing Replacing an vessel with a larger vessel 15 constructed of the same material The addition of a transfer system to a plant 16 currently without one 17 Adding a pump-out connection to a valve group Replacing a section of 6 schedule 40 A106 high 18 temperature piping with a 6 schedule 40 A53 pipe The change out of evaporator or condenser fans 19 from fixed speed to variable speed Changing an air unit from carbon steel to 20 stainless steel Replacing a Refrigerating Specialties evaporator pressure regulator (A4A) with a Hansen 21 evaporator pressure regulator (HA4A) of equal size Replacing a Hansen hand-expansion valve 22 with a Refrigerating Specialties handexpansion valve Replacing a Hansen H5600A x pressure relief valve (250 psi set pressure) with a Hansen 23 H5600R x pressure relief valve (250 psi set pressure) Replacing a clear sight glass with a reflex lens 24 sight glass both of the same material Replacing a screw compressor (e.g. a Frick 25 RWFII 399) with a factory re-built screw
2

IRC

May2009

Case

Description

MOC Required? Yes No

compressor on the same package. Adding a Bourdon tube pressure gauge to a 26 regulator temporarily in order to set the regulator Adding a Bourdon tube pressure gauge to a 27 regulator permanently in order to set the regulator Replacement of equipment that is no longer 28 made be the original manufacturer 29 Large scale replacement of an insulation system Examples of Procedure and Organizational Changes Re-setting suction pressure control set point but 30 still within the limits of operation as-defined in the process safety information Re-setting suction pressure control set point but 31 outside of the limits of operation as-defined in the process safety information 32 Modifying a standing operating procedure (SOP) Revisions to the inspection and test interval for 33 an ammonia detection system Outsourcing refrigeration operations and/or 34 maintenance 35 Reductions of refrigeration staffing levels Reducing the frequency of preventive 36 maintenance intervals for refrigeration equipment Examples of changes to Facilities that can impact a covered process Modifying racking in a warehouse equipped with 37 ceiling-hung evaporators The purchase and use of high lift fork trucks in 38 a refrigerated dock or warehouse Addition of battery chargers in or adjacent to a 39 machinery room Addition of a new non-refrigerated process line 40 within a plant 41 Reconfiguring office spaces in a plant Addition of an overhead crane in the engine 42 room
3

IRC

May2009

Case
43 Other 44 45

Description
Addition or re-arrangement of equipment within a plant (if it changes or affects escape paths for employees) Any changes that are generated as a result of a PHA, incident investigation, general safety review, or pre-startup safety review Replacement of equipment that is no longer made be the original manufacturer

MOC Required? Yes No