The Definition of Management of Change (MOC)

Definition of Management of Change (MOC)

Management of change (MOC) is a formal process for identifying, reviewing, approving and communicating changes to equipment, materials, processes, procedures, facilities or people before they are put in place. Its purpose is to make sure that any new or increased hazards created by a change are found and controlled before anyone is exposed to them.

Many serious industrial incidents have been traced back to changes that seemed small at the time, such as a substituted part, a modified procedure, a new chemical supplier or a temporary bypass that was never removed. MOC gives organizations a structured way to ask "what could go wrong?" before making the change.

In the United States, MOC is a required element of OSHA's Process Safety Management (PSM) standard, 29 CFR 1910.119(l), for facilities that handle highly hazardous chemicals, and of the EPA Risk Management Program. It is also a core part of ISO 45001 and many company safety management systems, and is widely used outside process industries for any significant operational change.

What Changes Need MOC

• Equipment and technology: new or modified machinery, piping, controls, alarms, software or safety systems.
• Materials: new chemicals, different suppliers or changes in concentration.
• Processes and procedures: new operating limits, revised work instructions or changes in production rates.
• Facilities: building modifications, layout changes or new traffic routes.
• Organization and people: reduced staffing, new shift patterns, contractor changes or loss of key experienced personnel.
• Temporary changes: short-term bypasses, workarounds or rentals, which must also be reviewed and have an end date.

A "replacement in kind," such as swapping a part for an identical one, usually does not need full MOC review, but the organization should define clearly what counts as in kind.

The MOC Process

1. Request: the person proposing the change describes what will change and why.
2. Screening: the change is checked to see whether it needs full review or is a replacement in kind.
3. Hazard review: a team with the right expertise identifies new or changed risks using tools such as hazard identification, a job hazard analysis or a formal process hazard analysis.
4. Controls: needed controls, procedure updates and drawing changes are defined.
5. Approval: authorized people sign off before work begins.
6. Communication and training: affected workers and contractors are informed and trained. See training matrix.
7. Pre-startup review: before the change goes live, the team confirms that everything is in place.
8. Close-out: records are updated and the change is closed, or temporary changes are reversed on schedule.

Example of Management of Change

A chemical plant wanted to increase production by raising the flow rate on a reactor feed line. The operations manager submitted an MOC request. The review team, including a process engineer, a maintenance lead and an operator, found that the higher flow would push a relief valve close to its capacity and that operators had never been trained on the new alarm limits.

The plant installed a larger relief valve, updated the operating procedure and alarm settings, and trained all shifts before the change was approved. A pre-startup review confirmed every action was complete before the new rate was introduced.

Frequently Asked Questions: Management of Change

Is MOC only for chemical plants?

No. MOC is required for many process facilities, but any organization can use it to manage risks from changes in equipment, procedures, staffing or layout.

Do organizational changes need MOC?

Yes, many organizations include organizational changes, such as staffing cuts or new shift patterns, in their MOC process because they can affect safety as much as equipment changes.

What is a temporary change?

A temporary change is one that is meant to last for a limited time. It still needs review, and it must have a set expiry date and a plan to return to normal conditions.