HOW LONG MANAGEMENT OF CHANGE (MOC) DOCUMENTATION SHOULD BE KEPT UNDER THE PSM STANDARD?
If an employer conducts an MOC related to changing procedures and practices [1910.119(l)(5)], OSHA would only require the employer to retain that particular MOC procedure until it is incorporated into the next process hazard analysis (PHA) revalidation or update required by 1910.119(e)(6). Therefore, in this case the MOC retention time is based on the PHA revalidation schedule which is established through consultation with employees [1910.119(c)(2)] and could be up to a maximum of 5 years. Addressing chemicals and equipment would become part of the Process Safety Information (PSI), giving employers a documented record of, not only the original design and design intent of the covered process, but also providing a record of all changes to the process that are of importance to those responsible for safe operation and maintenance and to those that may need to consider future changes to the process. Consequently, MOCs for chemicals or equipment in a covered process must be retained for the
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