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MOC

How to Implement Management of Change (MOC)

BY DAVE PAOLETTA
MARCH 1, 2020

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This article covers:

What Is Management of Change?

When is MOC Needed?

The Steps of MOC by Industry

MOC Resources

Change Management During MOC

How Can MOC Benefit Your Company?

Major change is bound to happen in any organization, no matter how big or small. Events
such as a transition in leadership, corporate expansion, product changes, or technical
equipment upgrades can have a dramatic impact.

Management of Change (MOC) is a formalized process for leading your employees through
a smooth and safe change process.

What Is Management of Change?

Management of Change (MOC) is a systematic approach to dealing with organizational

change, typically in industrial facilities and operations. The goal of this approach is to
safeguard workers from potential harm during the crucial period of transition.

In the United States, MOC is required for a relatively small subset of industrial companies.
However, any company seeking to control risk during process transitions or updates to
equipment can benefit from MOC. 

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The Risk of Change

biggest concerns that go along with managing organizational change.

A change to core processes, even temporary ones, can endanger the health and even the
lives of the workers. These risks are further magnified in companies dealing with chemical
substances and hazardous energy in their production system. 

It’s critical to recognize and define change before introducing it to the process.

MOC is a temporary safe program for any organization exposing workers to new hazards
through change.

Addressing Change Risk with MOC

Without MOC, change can become more painful and challenging than it already is. Sudden
changes in procedure and workflow can cause confusion among workers and contribute to

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process breakdowns.

While the concept sounds simple in theory, the reality is that organizations tend to either
ignore that changes are happening, or rush changes to just “get it over with.” In the
workplace, the focus is often on getting the job done, not on preventing risk.

The best argument for having an MOC process in companies not required to have one by
OSHA is risk recognition, which may involve safety, quality, production, or other key
performance areas.

In the environmental health and safety area, neglecting change management causes
management executives to fail to anticipate catastrophic events that can stem from the
change process.

MOC forces organizational leaders to take a step back, analyze proposed changes and
evaluate all of the potential risks. This allows them to develop a systematic plan on how to
prepare the organization to reduce or prevent those hazards. In other words, MOC is a
temporary safe program for the organization.

Examples of Changes to Manage with MOC

Since every company has different types of risk exposure and different tolerance for failures,
it is up to each business to analyze the hazards of the proposed changes and to define its
tolerance for risk.

A few examples of types of changes that should be assessed are:

Addition of new process equipment or critical business system (including software)

“Not in Kind” replacement of process equipment or parts
Modifications or minor additions to process equipment
Modifications or minor additions to infrastructure / non-process equipment
Changes to process control and/or instrumentation
Changes in critical process parameter operating limits
Alterations to safety systems (interlocks, shutdowns, fire or explosion suppression, etc)
Revisions to standard operating procedures (including emergency procedures)
Changes in site-level organizational structure

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Changes to maintenance procedures

Changes in raw material/component specifications or sourcing

To assess risk, engage a cross-functional team in a few hours of what-if brainstorming. Do

this early, while you’re still in the planning stage. Develop the definitions and examples that
apply to your situation and the risks your workers will be exposed to. 

If risks can be reduced with a formalized change process, MOC will benefit your
organization.

Agencies Involved With MOC

Management of Change can be implemented in any organization, but it is mandatory for

industries dealing with certain chemical hazards. Below are some government bodies that
deal with MOC compliance.

OSHA

The Occupational Health and Safety Administration (OSHA) is the primary agency
responsible for ensuring compliance with workplace safety guidelines in the United States.
This agency is in charge of implementing a systematic approach called Process Safety
Management (PSM) and does so under 29 CFR 1910.119.

Only certain industries are regulated under PSM, according to OSHA, “PSM applies to those
companies that deal with any of more than 130 specific toxic and reactive chemicals in
listed quantities; it also includes flammable liquids and gases in quantities of 10,000 pounds
(4,535.9 Kg) or more.”

It contains requirements and procedures for minimizing or eliminating threats arising from
dangerous chemicals. Compliance with PSM standards is important because it prevents the
negative effects associated with hazardous chemicals.

EPA

The United States Environmental Protection Agency (EPA) is another regulatory body that
implements risk management program guidelines. They deal mainly with organizations in

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danger of chemical-related accidents. Management Of Change (MOC) is a critical part of

the EPA’s chemical accident prevention program.

organizations must follow to ensure full compliance.

COMAH

The Control of Major Accident Hazards (COMAH) is the equivalent regulatory body in the
UK. Just like the OSHA and the EPA, their primary goal is to set forth safety guidelines and
standards for everyone to follow. Their primary objective is to prevent major accidents
(especially chemical-related accidents).

The COMAH also seeks to limit the effects of chemical hazards on the environment in the
event of any major accidents.

When is MOC Needed?

As outlined above, it’s important to identify circumstances when Management of Change

must be applied. Below are some of the situations and applications when MOC is needed.

Changes in Equipment Design

Whenever there is a change in the operational specifications of the equipment used within a
company, there is a greater danger for workers to make mistakes. Therefore, it’s important to
indicate the changes in equipment design (and specs) within the Process Safety Information.

Employers also need to come up with a safety plan on how to shield employees from
potentially adverse events arising from these changes. For example, if a piece of equipment
gets upgraded with a vital feature such as a valve installation or a new alarm, these require
MOC implementation.

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Use MOC to manage permanent or temporary change to facilities, personnel, training,

inspections/testing, processes, or equipment.

Changes in Operating Procedures

Each piece of equipment comes with step-by-step procedures on how to operate.

Furthermore, each aspect of work in a firm has systematic end-to-end procedures that
employees can simply follow and execute repeatedly.

Whenever operation guidelines or procedures are changed or updated by the company,

there is a risk for workers to continue with old processes because they are more used to it.

Years of following a particular process can lead to muscle memory, and employees may
enter a stage where they have difficulty adapting to new workflows. Of course, accidentally
following old procedures is extremely dangerous. MOC is also required in these situations.

Changes in Inspection and Test Maintenance Procedures

MOC is needed when a company’s way of inspecting and maintaining their equipment
changes. This ensures that employees don’t get exposed to chemically associated hazards.

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For example, procedures related to preventive maintenance of machines, an inspection of

piping, and servicing of equipment should be properly documented. Any changes to these

Facilities Changes

MOC is also required whenever there are changes to the facilities themselves. For example,
when a new structure is built close to a PSM-covered piece of machinery, or if it is modified
in some way, MOC must be performed. Proximity to machines and equipment can increase
the risk of accidents.

Temporary Changes

Temporary events such as the examples below require MOC:

Transfer of equipment to a temporary location due to infrastructure expansion

Temporary procedure changes due to the installation of new equipment features

Even though these changes will not become a part of your standardized processes, it is still
important to be prepared for any negative impact they may have on the organization, its
facilities, and its people.

It is also critical for organizations to close out any MOC documentation of a temporary
change or to update the program if the temporary change becomes permanent.

Hazard recognition is the most important aspect of successful MOC implementation. Rather
than hyper-focusing on the changes themselves, your goal is to anticipate and understand
the hazards that will arise from change. 

Likewise, all affected employees should be trained, equipped, and empowered to expose
hazards. 

The Steps of MOC by Industry

Management of Change is a major component of a bigger process called Process Safety

Management (PSM). Compliance with PSM as a whole requires a thorough knowledge of
MOC best practices and steps.

You’ll notice that hazard recognition is the most important step in successful MOC

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implementation. In this stage, the main focus is not on the actual changes that are
happening in the organization, but in anticipating and understanding the hazards that will

To do this, there must be a thorough review of things that could go wrong and how to
prevent those situations. There must also be a safety plan put into place if and when an
accident occurs.

Employers and organizational heads should never underestimate this process hazard
analysis stage. The overall success of MOC depends upon it.

Murphy’s Law states that “whatever could go wrong, will go wrong.” And so, people in charge
of MOC should put any risk or danger in consideration, no matter how unlikely they may be
to cause any significant trouble.

8 Steps To Management of Change

Although the specific process of MOC may vary a bit for each industry (there are different
types of MOC), the general steps are pretty much the same. 

Here’s the step by step rundown of what it takes to perform Management Of Change:

1. Recognize all changes. Without a thorough understanding of what changes are going to

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happen, it is difficult for a management team to evaluate its potential impact to the
organization. Know the details of the change, so that it can be properly managed.

potential hazard that the change will cause. Seemingly minimal effects should never be
overlooked. Instead, they should be treated as though they can impact the organization in a
big way. Worst-case scenarios for each risk must be identified, so that steps can be made to
avoid them.

3. Note hazards that can be minimized, controlled, or totally avoided. Management needs
to accept the reality that not all risks can be avoided. Some can only be managed or
reduced. It’s important to determine which risks can be totally avoided. Plans should then be
initiated to reduce or manage unavoidable hazards.

4. Find out if the change is feasible or can be implemented given the circumstances. This is
more like a risk-reward analysis. The management team can ask themselves, “Can the
changes be done with the least amount of danger possible, or do the hazards caused by the
change outweigh its rewards?”

5. Conduct a Pre-Startup Safety Review (PSSR). The PSSR is a thorough review of

equipment and its related processes to ensure that safety measures are in place. It is most
often used in processes involving chemical substances. This is more like a verification check
of the entire rocket ship before take-off (you get the picture).

6. Implement the change — if safe to do so. The organization must implement the change,
knowing all the risks in advance and how it might impact the workers. The goal of
responsible leadership must be to help employees smoothly glide through the painful
process of change without endangering them. Emergency measures should also be in place
if a potential accident turns into a real one.

7. Train all affected workers. Any involved employee, as well as all managers who will
execute your new processes, should be carefully trained on the new procedures. More
knowledge and hands-on-training will lead to fewer or zero instances of mishaps, or to less
serious consequences when failures occur.

8. Follow new procedures and continue to evaluate feedback from the ground. As changes
are rolled out, management should continue to evaluate the worker’s exposure to risk. This
can be receiving continuous feedback and reports from the organization’s day-to-day

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operations.

Ideally, employers conducting MOC have already anticipated workforce safety issues even
before changes are introduced.

The above general steps may vary a bit depending on the type of MOC required. The three
most common types are administrative MOC, organizational MOC, and technical MOC.

Industry-Specific Steps

For companies requiring MOC procedures under OSHA, documentation is a critical

component. Petroleum, pyrotechnics/explosives, storage facilities, and small businesses
dealing with hazardous chemicals each have unique demands surrounding change. 

Petroleum, explosives, refrigeration, and other companies storing or dealing with hazardous
chemicals are required by OSHA to document their MOC procedures.

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Petro-Specific MOC

The technical basis for the change

The impact on safety and health
Modifications to operating procedures
The necessary time period for change
Appropriate authorizations
Training of affected employees

These written descriptions may be used to fulfill the OSHA requirements for MOC. Be sure to
include all relevant changes in your documentation and MOC process. 

Some commonly (and unlawfully) overlooked changes include:

Installing a control valve bypass

Installing a spill guard berm under a fracturing tank along with
proper grounding and bonding
Changes to an alarm set point
Changes to materials of construction
Changing procedures for the manual addition of methanol to a
chloride injection tank
Procedures for installing a new type of relief device
Changing inspection intervals for piping circuits
Changing the number of thickness measurement locations (or
condition monitoring locations) on a pipe
Changes to a control room located within a PSM covered
process unit

The full guidelines and requirements for petro-specific MOC are discussed in this procedure
document for petroleum refineries.

Explosives Manufacturing MOC

Those who manufacture explosives and pyrotechnics are required by OSHA to regularly
inspect their equipment. Each thorough inspection must be properly documented to serve as
proof of PSM compliance. The recorded inspection data may also be used to assess the

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long-term degradation of equipment after many years of use.

implemented. The employer will be required to assess and document the potential hazards
of continued usage.

MOC For Small Businesses

Small business changes require MOC if the development and distribution of their products
expose their workers to hazardous chemicals.

Here are some examples of hazardous chemicals which may be used by small businesses:

Asphalt paving or roofing materials

Pharmaceuticals and/or byproducts 
Plastics and rubber
Stone, glass, and concrete
Other chemical products

The MOC process for small businesses don’t vary much from that required in other business
types. However, many small business owners are still not fully aware of process safety
management standards.

MOC For Storage Facilities

OSHA requires storage facilities to conduct a process hazard analysis to ensure that
hazardous chemicals are properly handled within designated storage areas.

Some of the factors that need to be considered are:

Incompatible materials should be separated, especially combustible materials that might

cause a fire.
Temperature levels must be ideal for the type of chemicals being stored.
High temperatures for flammable materials should be avoided, while extremely low
temperatures that could hurt the integrity of certain chemicals should be prevented as
well.
Storage areas must maintain a safe distance from fire zones.

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If an outdated operation is discovered in the storage procedure, employers must develop

and implement MOC to address the issue. The newly updated process must undergo the

MOC Resources

The most valuable resources for MOC management are information/assistance provided by
your regulatory body, MOC checklists and forms, and safety management software. 

MOC Forms

Your company’s change request process likely has an official form that allows you to
officially initiate and monitor the process.

If you haven’t already, create a change request form to support the applicable steps of MOC
(1-4):

1. Recognize all changes.

2. Identify hazards and risks.
3. Note hazards that can be controlled or minimized (and how).
4. Find out if the change is feasible given the circumstances.

If you don’t already have a Change Request Form or MOC Change Form, you can customize
this template.

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Click to download the MOC Change Request Form PDF

Your change form should include sections for:

Requester’s contact info and date of submission

Description of the proposed change
Rationale and data to support the change
Hazard identification and risk assessment of change
Hazards and risks associated with not changing
Business impact of proposed change, including cost
A list of all persons responsible for the change procedure
Estimated duration of change and proposed start and end dates
A place for stakeholders to sign off on your request

When every change is documented from the moment it’s introduced, management can
easily review records when needed. 

MOC Checklists

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Checklists allow you to facilitate and oversee your MOC plan. 

Click to download the PSSR Checklist Excel File

Search the Safesite template library for more MOC checklists, or upload your own for free.

Safety Management Software for MOC

Safety Management software is designed to support safety processes like training,

inspections, and hazards. You can use software like Safesite to reduce the paperwork and
improve hazard recognition related to your MOC process.

For example, as you conduct your PSSR, you can use data from mobile inspections (including
images of hazards and equipment inspection logs) to inform your assessment. You can also

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use a master PSSR checklist to ensure you’ve completed every step.

Document employee training and attendance related to the train so no worker is left behind.
Finally, report and share near misses with your team to prevent incidents. 

Through real-time reports and notifications, management will be able to monitor all aspects
of the change and recognize warning signs before something goes awry.

OSHA MOC Resources

OSHA provides a dedicated resource page for Process Safety Management, which includes

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Management of Change. Pages dedicated to applicable standards, hazard recognition, and

evaluation/control outline common hazards and provide insight into changing your

This section also houses OSHA publications for covered industries, including petroleum,
explosives, small business, storage facilities, and chemical facilities. This literature includes
ways to remain in compliance with OSHA standards, but it may also be helpful if you’re not
explicitly covered under the PSM standard. 

For example, Process Safety Management for Petroleum Refineries lists commonly
overlooked changes. Choosing to upgrade equipment, changing emergency procedures, and
changing valves/switches are just a few changes that many companies — not just oil and
gas — choose to make without a documented MOC plan. The resulting risks to workers’ lives
could be avoided with Management of Change. 

OSHA also has an electronic newsletter, QuickTakes, which helps employers stay updated on
recent developments in the field.

Assistance is also provided to non-English-speaking employers via the Spanish version of the
website.

The OSHA Outreach Training Program offers courses and seminars for the general public.
Courses may take 1-4 days to complete. They discuss the most important areas of PSM
compliance, such as:

Hazardous materials
Machine safety
Construction topics
PSM documentation
And many others

Sending your staff to undergo these courses, or attending them yourself, can be a great help
to your organization.

If you need a more hands-on approach to MOC compliance, you can try OSHA’s Onsite
Consultation Program. With this free and confidential assistance service, your company will
be visited by an OSHA compliance assistance specialist to help identify areas of potential
hazards within your workplace.

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The assistance specialist will then provide suggestions on how you can comply with agency
standards. You will also receive tips for improving workplace safety and how to facilitate

Third-Party PSM Compliance Assistance

If you prefer to limit the OSHA’s involvement during your internal review of your
organization’s hazards and safety measures, you can opt to seek the help of third-party
compliance assistance specialists.

These third-party assistance specialists are private entities that are not affiliated in any way
with the OSHA. They provide a variety of consulting services that will help your organization
improve in all aspects of PSM. They can also suggest standard procedures that you can
implement in your company. This is not just for OSHA compliance purposes, but for the
overall safety of your employees as well.

To select a Process Safety Management (PSM) and Management of Change (MOC) team
lead or consultant, look for individuals with field management experience. Knowledge of the
specific hazards you’re dealing with — and the safety training required to address those
hazards — is also critical. 

Change Management During MOC

So far, we’ve talked about Management of Change (MOC). It deals with the technical side of
change and how to avoid or minimize risks arising from changes in equipment, process, and
handling of chemicals.

However, change also has a ‘people aspect’, wherein the role of management is to influence
people’s behavior in reaction to technical changes.

Dealing with the people side of change is known as Change Management (CM). The
challenge for any organization is to smoothly perform change management during MOC.

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To effectively differentiate MOC and CM, it’s important to note that change management’s
main goal is to effectively guide people to transition from a past/present state to a future
desired state.

For example, if the manual operations required to be performed are reduced due to more
advanced equipment introduced within the company, Management of Change (MOC) is
needed to document the changes in processes, equipment handling, and associated risks
involved.

On the other hand, Change Management (CM) is required to deal with the impact of the
change on the individual operating the equipment itself. Because lesser manual operations
are now required on his end, the employee’s workload may decrease. This may lead the
company to add more items to his job description. In more severe circumstances, the
company might have no choice but to initiate a reduction in pay or even declare the
position as redundant.

These types of changes to work circumstances can impact the behavior of employees. The
goal of Change Management is to minimize the risks associated with people’s behavior
during changes. This can be done by using the following managerial elements:

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Effective communication
Competent leadership

To smoothly transition through major changes in an organization, employers and managers

should implement a good balance of MOC and CM. This ensures that both the technical
side and people side of change are dealt with simultaneously.

How Can MOC Benefit Your Company?

It’s true that evaluating and documenting organizational change can be time-consuming
and costly. But it’s 100% worth it.

Equipment and facilities will eventually fail, and people will be exposed to chemical, health,
and other job-related risks when they do. It’s your job to protect your employees, both
legally and because it’s the right thing to do.

Expect changes to happen, and execute the Management of Change (MOC) steps to keep
your organization thriving. Use safety management software to ease your administrative
burden, increase visibility, monitor your new process — and repeat. 

Related Blog Posts

Discover all articles

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By Dave Paoletta
David Paoletta, MS, MBA, CSP, CUSP, is a research analyst and subject matter
expert for Safesite, a safety management software company based in San
Francisco, CA. He is also a principal consultant with New Dimensions in Safety in
Alameda, CA. David has extensive utility field safety experience with PG&E and
PNM New Mexico. He is a Past NM ASSE SPY Award winner and a Past President of
the San Francisco Chapter ASSE.

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