MOC Requirements
by Regulation

Scope and Applicability

Applies to facilities that handle highly hazardous chemicals above threshold quantities. The Process Safety Management standard is the foundational MOC regulation in the United States and establishes the requirements that most other standards build upon.

Required MOC Elements

OSHA PSM requires written procedures to manage changes (except replacements-in-kind) to process chemicals, technology, equipment, and procedures. Before any change is implemented, the employer must address:

• The technical basis for the proposed change
• Impact of the change on safety and health
• Modifications to operating procedures
• Necessary time period for the change
• Authorization requirements for the proposed change

Additionally, employees involved in operating a process and maintenance and contract employees whose job tasks will be affected must be informed of, and trained in, the change prior to startup.

Scope and Applicability

Applies to facilities that use regulated substances above threshold quantities under the EPA Risk Management Program. The MOC requirements under RMP are nearly identical to OSHA PSM, as the EPA modeled its rule after the OSHA standard.

Required MOC Elements

EPA RMP requires the same five considerations as OSHA PSM (technical basis, safety and health impact, procedure modifications, time period, and authorization). The primary difference is focus: while OSHA PSM protects workers, EPA RMP is designed to protect the public and the environment from offsite consequences of chemical releases.

• Written MOC procedures covering changes to process chemicals, technology, equipment, and procedures
• Employee notification and training before startup of the changed process
• Update of process safety information to reflect the change

Scope and Applicability

ISO 45001 is the international standard for occupational health and safety management systems. Unlike OSHA PSM, which targets specific high-hazard industries, ISO 45001 applies to any organization seeking to improve OH&S performance.

Required MOC Elements

ISO 45001 Section 8.1.3 requires organizations to establish a process for the implementation and control of planned temporary and permanent changes that can impact OH&S performance, including:

• New products, services, and processes, or changes to existing products, services, and processes (including work locations, work organization, working conditions, equipment, and workforce)
• Changes in legal requirements and other requirements
• Changes in knowledge or information about hazards and OH&S risks
• Developments in knowledge and technology

The standard also requires the organization to review the consequences of unintended changes and take action to mitigate any adverse effects, as necessary (Section 8.1.3).

Scope and Applicability

ISO 14001 is the international standard for environmental management systems. Its MOC requirements focus on changes that could affect environmental aspects and impacts.

Required MOC Elements

ISO 14001 Section 8.1 requires organizations to control planned changes and review the consequences of unintended changes, taking action to mitigate any adverse effects. Specifically, organizations must consider:

• Changes to processes or the environmental management system
• Potential environmental impacts of planned changes before they are introduced
• Actions to mitigate adverse environmental effects from unintended changes

Scope and Applicability

API RP 1173 provides a framework for pipeline safety management systems. It applies to operators of hazardous liquid and gas pipelines and includes management of change as a core element.

Required MOC Elements

API RP 1173 requires operators to establish a management of change process that:

• Identifies changes that could affect pipeline safety before they are implemented
• Evaluates the risks associated with those changes
• Ensures appropriate review and approval
• Communicates changes to affected personnel
• Documents the change management process
• Covers changes to technology, equipment, procedures, and organizational structure

Scope and Applicability

The COMAH regulations apply to establishments in the United Kingdom that store or use dangerous substances above specified thresholds. COMAH is the UK equivalent of the EU Seveso III Directive.

Required MOC Elements

COMAH requires operators to identify and evaluate major accident hazards, including those that arise from changes. Specifically:

• The safety report must address the management of change within the safety management system
• Modifications to installations, processes, or storage that could have safety implications must be assessed before implementation
• Changes to organizational structure and staffing that could affect safety must also be managed

Practical Approach

• Design for the superset — Build your MOC forms and workflows to capture the broadest set of requirements. If you need to satisfy both OSHA PSM and ISO 45001, your forms should cover both process changes and organizational changes.
• Use conditional logic — Not every change needs every question. MOC software with conditional logic can show OSHA-specific fields only when the change involves highly hazardous chemicals, and ISO-specific fields only when the change affects your management system.
• Map regulatory citations — For each section of your MOC form, document which regulatory requirement it satisfies. This makes audits straightforward and demonstrates intentional compliance rather than coincidental overlap.
• Train by regulation — Help reviewers understand which regulatory lens to apply based on the type of change. Environmental reviewers need to think about ISO 14001 and EPA RMP impacts, while safety reviewers focus on OSHA PSM and ISO 45001.