Management of Change (MOC) is a critical element of process safety management that ensures changes to processes, equipment, technology, procedures, and facilities are properly evaluated for hazards before implementation. OSHA’s Process Safety Management standard (29 CFR 1910.119(l)) and EPA’s Risk Management Program (40 CFR 68.75) require covered facilities to establish MOC procedures. However, MOC best practices apply broadly to any organization managing hazardous processes, complex operations, or safety-critical systems. Inadequate management of change is a contributing factor in many major industrial incidents. A program-level audit evaluates whether your organization has effective procedures for identifying changes, evaluating hazards, obtaining proper authorization, updating affected documents, training affected employees, and conducting pre-startup safety reviews.
Free Management of Change Program Audit Checklist
Download our Word document checklist for management of change program audits.
Download Checklist (.docx)Regulatory Requirements
29 CFR 1910.119(l) — Management of Change (OSHA PSM)
OSHA’s PSM standard requires covered employers to establish written procedures for managing changes (except replacement in kind) to process chemicals, technology, equipment, and procedures. MOC procedures must address the technical basis for the proposed change, impact on employee safety and health, modifications to operating procedures, necessary time period for the change, and authorization requirements. Employees affected by the change must be informed and trained before startup of the changed process.
40 CFR 68.75 — Management of Change (EPA RMP)
EPA’s Risk Management Program requires essentially the same MOC elements as OSHA PSM for covered facilities. The EPA rule applies to facilities with more than a threshold quantity of regulated substances and requires MOC procedures addressing the same elements: technical basis, safety and health impact, procedure modifications, time period, and authorization. The EPA rule also requires updating process safety information and operating procedures.
Industry Standards and Best Practices
Beyond regulatory requirements, MOC is a fundamental element of process safety management frameworks including CCPS (Center for Chemical Process Safety) guidelines, API RP 75 (Recommended Practice for Development of a Safety and Environmental Management Program), ISO 45001 Clause 8.1.3 (Management of Change), and the Seveso III Directive (EU). These frameworks often extend MOC beyond process changes to include organizational changes, personnel changes, and temporary changes.
MOC Procedures and Program Structure
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Written MOC procedures | Written MOC procedures are established and maintained per 1910.119(l). Procedures address: the technical basis for the proposed change, impact of change on safety and health, modifications to operating procedures, necessary time period for the change, and authorization requirements for the proposed change. Procedures clearly define what constitutes a change versus a replacement in kind. |
| Change definition and scope | The MOC program clearly defines what types of changes require MOC review. At minimum, changes to process chemicals, technology, equipment, and procedures are covered per 1910.119(l). Best practice extends MOC to organizational changes, staffing changes, temporary changes, facility changes, software/control system changes, and changes to safety-critical equipment. The definition of replacement in kind is clear and consistently applied. |
| Temporary change management | The MOC program addresses temporary changes with the same rigor as permanent changes. Temporary changes have defined time limits and expiration dates. Procedures exist for extending temporary changes beyond their approved duration. If a temporary change becomes permanent, a new or updated MOC is initiated. Expired temporary changes are restored to the original condition. |
| MOC roles and responsibilities | Roles and responsibilities are clearly defined for MOC initiators, reviewers, technical evaluators, approvers, and those responsible for implementation and close-out. Approval authority levels are appropriate for the risk level of the change. The MOC program designates who can authorize changes and establishes escalation procedures for high-risk changes. |
Change Identification and Hazard Evaluation
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Change identification | Processes exist to identify changes before they are implemented. Work order systems, project management processes, and maintenance procedures include MOC screening questions. Employees are trained to recognize when a change requires MOC review. Near-miss and incident investigations evaluate whether an unmanaged change was a contributing factor. |
| Hazard evaluation | Each proposed change undergoes a hazard evaluation addressing the technical basis for the change and its impact on safety and health per 1910.119(l)(1). The depth of hazard evaluation is proportional to the complexity and risk of the change. Evaluation methods may include What-If analysis, HAZOP, checklist review, or other appropriate methods. The evaluation considers potential process safety, personnel safety, environmental, and operational impacts. |
| Risk assessment and mitigation | Risks identified through the hazard evaluation are assessed and appropriate mitigation measures are developed. Risk controls follow the hierarchy of controls. Residual risks are documented and accepted at the appropriate authority level. Action items from the hazard evaluation are tracked to completion before the change is implemented. |
Authorization and Documentation
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Change authorization | Changes are authorized by appropriate personnel per 1910.119(l)(5) before implementation. The authorization process verifies that hazard evaluation is complete, action items are resolved, affected documents are updated, affected employees are trained, and pre-startup safety review requirements are met. Authorization is documented with signatures and dates. |
| Process safety information updates | Process safety information (P&IDs, equipment specifications, chemical data, process parameters) is updated to reflect the change per 1910.119(d). Updates are completed before or concurrent with the change implementation. Documents affected by the change are identified in the MOC package. Document revisions are tracked and controlled. |
| Operating procedure updates | Operating procedures affected by the change are revised per 1910.119(f) and 1910.119(l)(3). Revised procedures are reviewed and approved before the changed process is started up. Employees are trained on revised procedures. Procedure revisions clearly identify what has changed. |
| MOC documentation and tracking | Complete MOC packages are maintained including the change request, hazard evaluation, risk assessment, action items, approvals, affected document list, training records, and pre-startup review. An MOC tracking system (register or database) provides visibility into all open, in-progress, and completed MOCs. MOC packages are retained for the life of the process or per records retention requirements. |
Training and Communication
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Employee notification | Employees whose job tasks are affected by the change are informed of and trained on the change before startup per 1910.119(l)(4). Notification covers what is changing, why, any new hazards or modified procedures, and any changes to their roles or responsibilities. Communication methods are appropriate for the workforce (shift meetings, written notices, training sessions). |
| Affected employee training | Training on the change is provided to all affected employees including operators, maintenance workers, contractors, and emergency responders per 1910.119(l)(4). Training covers modified operating procedures, new equipment or controls, new hazards, and changed emergency procedures. Training is documented with attendee names, dates, and topics covered. |
| Contractor notification | Contractors working in or near the affected area are notified of changes that may affect their safety per 1910.119(h). Contractor employees receive appropriate training on changes that affect their work scope or safety. Contractor notification is documented. |
Pre-Startup Safety Review and Close-Out
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Pre-startup safety review | A pre-startup safety review (PSSR) is conducted per 1910.119(i) for new and modified facilities. The PSSR confirms that construction and equipment are in accordance with design specifications, safety/operating/maintenance/emergency procedures are in place, a process hazard analysis has been performed and recommendations resolved, and training has been completed. The PSSR is documented and authorized before the process is started. |
| MOC close-out | A formal close-out process verifies that all MOC requirements have been met before the change is considered complete. Close-out verifies: all action items are resolved, documents are updated, training is complete, PSSR is performed (if required), and the change is functioning as intended. Close-out is documented with responsible party sign-off. |
| Post-implementation review | For significant changes, a post-implementation review is conducted to verify the change is performing as intended and no unintended consequences have occurred. Review timing is appropriate for the type of change (typically 30–90 days after startup). Lessons learned are captured and fed back into the MOC program. |
Program Review and Improvement
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| MOC program audit | The MOC program is audited at least every three years as part of the PSM compliance audit per 1910.119(o). Audit evaluates procedure adequacy, implementation consistency, documentation completeness, training effectiveness, and timeliness of change reviews. Audit findings drive corrective actions and program improvements. |
| MOC metrics and trending | Key metrics are tracked to evaluate MOC program performance including: number of MOCs initiated and completed, average review/approval cycle time, overdue MOCs, action item closure rates, and incidents attributed to unmanaged changes. Trends inform program improvement and resource allocation. |
Corrective Actions
Common Issues and Responses
- No written MOC procedures: Develop written MOC procedures addressing all requirements of 1910.119(l). Define change types, review processes, hazard evaluation methods, authorization requirements, and documentation standards. Train all affected personnel on the new procedures before implementation.
- Changes implemented without MOC: Conduct a retrospective MOC review for the unapproved change. Perform a hazard evaluation and address any identified risks. Update affected documents and train affected employees. Investigate why the change bypassed MOC and strengthen identification processes.
- Incomplete hazard evaluations: Review and enhance hazard evaluation procedures. Ensure evaluation depth matches change complexity. Train evaluators on appropriate methods (HAZOP, What-If, etc.). Implement peer review of hazard evaluations for complex changes.
- Outdated operating procedures: Conduct an audit of all operating procedures against recent MOC records. Update procedures that were not revised after changes. Implement a systematic check in the MOC process that verifies procedure updates before authorization.
- Employees not trained on changes: Review MOC records to identify any changes where employee training was not completed. Provide training retroactively where needed. Strengthen the MOC process to prevent authorization of change startup before training verification.
Download the Free Checklist
Get our management of change program audit checklist in Word format. Customize it for your organization.
Download Checklist (.docx)Ecesis EHS Software
Management of Change
Digital MOC workflows with hazard evaluation, approval routing, action item tracking, and automated notifications.
Process Safety Management
Integrated PSM platform connecting MOC with PHA, operating procedures, incident investigation, and compliance audits.
Training
Track change-specific training requirements, affected employee notifications, and training completion verification.
Task Management
Action item tracking from MOC hazard evaluations with assignee, deadline, and completion documentation.
Document Management
Controlled document system for P&IDs, operating procedures, and MOC packages with revision tracking.
Compliance Calendar
Schedule MOC reviews, PSSR deadlines, post-implementation reviews, and PSM compliance audit cycles.
