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PSM requirement around MOC

PSM requirement around MOC

(OP)
I'm currently working on upgrading our PSM system. One of my questions is around when an MOC is needed when updating operating procedures.

Right now, there is no procedure on what is needed to create and revise an operating procedure. We've just been writing an MOC each time.

My plan was to create a procedure for how to create and revise operating procedures - this would include a template so that all the PSM elements would be covered. I was going to include that when a procedure needed to be revised, it would just have to go through the normal sign-off procedure and that no MOC would need to be written for it (this also includes having the changes communicated to everyone). For creation of a procedure, a MOC would have to be written.

My question is would this be allowed? I know that for any changes (revision in procedure) an MOC is needed, but I would have an official document saying that the MOC is not needed for the revisions.

RE: PSM requirement around MOC

Stay with the MOC. It is something that the site people are used to seeing - no training on the new documentation requirements. MOC process is already in place - no further time & effort required. And whatever you end up setting for a procedure in lieu of MOC, that new procedure/documentation method will end up looking like an MOC. It is pretty unavoidable since you will need a 'review' signature and an 'approval' signature, and are required to 'train' everybody that is affected [or may be affected] by your document revision. Keep it simple - use your MOC.

RE: PSM requirement around MOC

No it would not be allowed and in essence you are merely creating another document that needs to be reviewed and certified annually. It is a great idea to have an overall procedure to ensure all PSM documents are setup and managed properly so I would recommend including this in your highest level PSM/RMP management system; but it in NO WAY allows you to by-pass the MOC process when it comes to revising or creating new procedures.

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