When a business changes how it operates (procedures, equipment, materials, or facilities) those changes can introduce new risks. That is where Management of Change comes in. In some industries, MOC is required under Process Safety Management (PSM) regulations. In others, it is used because experience has shown that unmanaged change is a common cause of incidents.
Even where it is not required, companies often rely on a written MOC risk assessment to pause the work and evaluate potential impacts before moving forward.
What is Management of Change (MOC)?
Management of Change (MOC) is a structured way to review changes that could affect safety, health, or operations. While it is most common in industrial and chemical settings, the same principles apply anywhere change alters how work is done or how equipment is used.
The purpose of MOC is to identify hazards created by a change, evaluate the risk, and apply controls before the change occurs. It also produces documentation that shows what was reviewed and approved, which becomes relevant during audits, inspections, or investigations.
How Can MOC Benefit Your Company?
- Improve safety by identifying hazards before work changes are made.
- Document decisions so approvals and controls are clearly recorded.
- Clarify communication for employees affected by the change.
- Limit disruption by addressing problems before implementation.
- Reduce overall risk tied to injuries, incidents, or equipment damage.
When Management of Change Programs Required?
An MOC is required when changes affect certain core elements of an operation. When one of these elements changes, an MOC review is typically triggered. If the change is proposed but never implemented, the MOC can usually be closed without completing the full Management of Change process.
The five elements of MOC requirements are:
- Processing chemicals
- Changes in the company’s technology
- Changes to the facilities
- Changes to company procedures
- Changes in equipment
Temporary vs. Permanent Changes
From a regulatory and risk standpoint, temporary changes are treated the same as permanent ones if they affect covered elements. Temporary changes should have a defined duration and be reviewed again if they are extended or become permanent. Many compliance issues start when temporary changes remain in place without reevaluation.
Federal Agencies That Deal with MOC Compliance
Industries that handle specific chemicals must conduct a risk assessment. However, any business can initiate a MOC, even if it’s not mandatory. Two federal agencies oversee MOC compliance.
EPA
The Environmental Protection Agency (EPA) mainly watches over industries with a risk of chemical accidents. So, doing a MOC is important for the federal agency’s program to prevent chemical accidents.
OSHA
The Occupational Health and Safety Administration (OSHA) manages workplace safety compliance. Under OSHA’s Process Safety Management standard (29 CFR 1910.119(l)), employers must establish and implement written procedures to manage changes to process chemicals, technology, equipment, procedures, and facilities. OSHA expects employers to evaluate the technical basis for the change, assess safety and health impacts, update procedures as needed, define the time period for the change, and document required authorizations. This requirement applies to facilities that handle any of the listed 130 chemicals.
8 Steps to a MOC Process
The Management of Change process involves eight key steps to ensure a systematic and safe approach to implementing changes in a workplace. The process might vary according to the industry, but the principle is the same.
1. Identify Proposed Changes
Know the proposed changes and how the business will be affected so they can be managed with minimal to no impact on the company.
2. MOC Risk Assessment
Conduct a thorough risk assessment to identify and evaluate potential hazards associated with the proposed change. Analyze the risks to determine the best mitigation strategies.
3. Determine if Hazards/Risks Can Be Controlled
Not all risks are preventable. Companies can only manage or minimize some. However, it’s not easy to classify risks, which is where the Hierarchy of Hazard Control can help. This classification method helps categorize hazards so you can create practical plans to minimize unavoidable risks.
4. Evaluate Making a Change
Determine if the change is cost effective regarding cost, safety, hazards, and impact. Like risk analysis, management decides if the rewards outweigh the risks.
5. Implement Change If Safe
If the rewards are greater than the risks, start implementing the change. Employees must be aware of the changes, and management should be able to guide them smoothly through the transition. Employee safety is key, and companies should have the necessary backup emergency services and safety training in place.
6. Pre-Startup Safety Review (PSSR)
This step mainly applies to the chemical industry. A Pre-Startup Safety Review (PSSR) is required for all equipment and related practices. It verifies that all safety measures are implemented.
7. Train Workers on Change
All managers and employees affected by the implemented changes require training on the new processes and procedures. Hands-on training, as well as written reminders, will help prevent accidents. If you need expert help, our full service safety management services can keep your workforce prepared.
8. Execute and Monitor Change
As the changes are implemented, management needs to continually monitor employee risks. Feedback from workers and reports from daily operations managers will help organizations know if their employees are exposed to potential hazards.
By following this Management of Change checklist, organizations can systematically manage changes, prioritize safety, and ensure a smooth transition in the workplace.
Examples of Changes that Require an MOC
Here are some common changes that typically trigger an MOC:
- Replacing equipment with a different model or capacity
- Changing chemicals, raw materials, or suppliers
- Updating control systems or software
- Modifying operating limits or set points
- Revising procedures that affect task steps or safeguards
Safety By Design Can Help Prioritize Workplace Safety
Management of Change is a lengthy procedure with several time consuming steps for companies with limited experience identifying the risks a change could bring.
As a top safety company in Houston, Safety By Design supports MOC efforts through site safety inspections, safety program development, annual safety program reviews, and online OSHA training services that align with regulatory and operational requirements.
Contact a safety specialist today to see how we can help!
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