Temporary changes, including bypasses, jumpers, defeated instruments, and other short-duration deviations from design intent, are explicitly required to follow the MOC process under 29 CFR 1910.119(l). OSHA has been clear that the word temporary describes the intended duration of the change, not a reduced level of hazard review. Many of the worst process safety incidents have involved temporary changes that became permanent through neglect, or that were made without authorization. These letters address what constitutes a temporary change, the documentation required, time limits, and what happens when a temporary change outlives its authorization.
What OSHA Has Said
⚡ Key Compliance Takeaway
Temporary changes require full MOC treatment. Set a hard expiration date, document the hazard review, and ensure operators are informed. If a temporary change has been in place for more than a few weeks, treat it as permanent and reopen the MOC process.