Safety Evaluations in the Management of Change Process

This paper looks at how safety evaluations used at commercial and Department of Energy (DOE) nuclear facilities can be used in the Occupational Safety and Health Administration’s (OSHA) management of change process. The paper can be viewed from either the regulator’s or facility owner’s perspective. Preventing and minimizing consequences relating to highly hazardous materials does not stop with the collection of process safety information and the preparation of a process hazard analysis. Process changes evaluated against process safety information may lead to increases in the probability or consequences of catastrophic releases contained in the process hazard analysis. A comparison is presented of the management of change process used at process facilities versus those used at nuclear facilities. The results of the comparison show that the safety evaluation offers process facilities an alternative approach in performing a final check on a process change that could confirm that no unreviewed hazards exist.