Management of Change questions for the ASP
ASP Domain 2: Safety Programs and Concepts (2.10 Management of change). 3 free questions below. Every answer quotes and links the regulation it comes from.
Regulations covered
- 29 CFR 1910.119 Process safety management of highly hazardous chemicals.How this section is tested
Regulation text pulled from the eCFR, current as of 2026-10-14.
Question 1
A chemical plant that operates a covered process plans to replace a worn pump seal with an identical seal from the same manufacturer. A second project would switch the same process to a different catalyst that has different reactivity. The safety manager must decide which of these two jobs needs the written management of change procedure. Which choice is correct?
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Answer: C. Only the catalyst switch needs it, because the identical seal is a replacement in kind
OSHA's process safety management standard requires written change procedures for changes to process chemicals, technology, equipment and procedures, except replacements in kind. The identical seal is a replacement in kind. The new catalyst changes a process chemical, so it is covered. The other choices wrongly exclude chemicals, cover everything, or cover nothing.
On the job
At a refinery with a covered process, an EHS manager is handed two work requests: swapping a failed gasket for an identical one, and replacing a solvent with a different one in the same process. The gasket swap is a replacement in kind, so it is excluded from the written change procedures. The solvent substitution changes a process chemical, so the manager requires the written management of change procedure before work begins.
Study aid, not site-specific safety advice. The official rule controls.
Answer C comes from
29 CFR 1910.119(l)(1)(opens ecfr.gov in a new tab)“The employer shall 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.”
Question 2
A refinery wants to raise the operating temperature of a covered process to increase output. The engineering group has written the technical basis for the change and listed the operating procedure edits. The change request has not yet been reviewed for its effect on safety and health, and no one has set who must authorize it. The supervisor wants to start the change this week. What must happen first?
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Answer: B. Address the safety and health impact, the time period needed, and the authorization requirements before the change
OSHA's process safety management standard says the change procedures must make sure all listed considerations are addressed before any change: technical basis, safety and health impact, operating procedure changes, time period, and authorization. Reviewing afterward, skipping authorization, or covering only authorization all leave required items unaddressed before the change.
On the job
An EHS manager at a chemical plant receives a request to swap a reactor cooling coil for a different design in a covered process. The package includes a technical basis and revised operating procedures, but nothing on safety and health impact, the time period for the change, or who authorizes it. Under the process safety management standard, those considerations must be addressed before any change, so the manager holds the work until they are documented.
Study aid, not site-specific safety advice. The official rule controls.
Answer B comes from
29 CFR 1910.119(l)(2)(opens ecfr.gov in a new tab)“The procedures shall assure that the following considerations are addressed prior to any change:”
Question 3
A plant that runs a covered process installs a different type of control valve, which changes how operators bring the unit up. The change is approved and finished. Maintenance technicians and a contract instrument crew will service the new valve. Start-up is set for tomorrow morning. Which action is required before the affected part of the process starts up?
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Answer: A. Inform and train the operators, maintenance employees and contract employees whose tasks the change affects
OSHA's process safety management standard requires operating, maintenance and contract employees whose tasks are affected by a change to be informed and trained before start-up of the process or affected part. Limiting training to operators, training after start-up, or waiting for the annual refresher all miss that timing and coverage.
On the job
At a chemical plant covered by process safety management, a plant engineer finishes replacing a pump seal system, which changes how operators line up the unit. Before the affected part restarts, the engineer schedules a briefing and training session. It includes the operators, the maintenance mechanics, and the contract pipefitters, because the change affects their tasks and training must come before start-up.
Study aid, not site-specific safety advice. The official rule controls.
Answer A comes from
29 CFR 1910.119(l)(3)(opens ecfr.gov in a new tab)“Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process.”