The oil and natural gas, chemical, and manufacturing industries are subject to OSHA's Process Safety Management (PSM) standard (29 CFR 1910.119), which requires employers to identify, evaluate, and control hazards associated with highly hazardous chemicals. Implementing a Management of Change process is a critical component of PSM compliance.
How MOC Supports PSM Compliance
Implementing an effective MOC process helps guide PSM compliance by ensuring that risks are evaluated and controlled before introducing changes to materials, procedures, technology, equipment, facilities, personnel, or budgets. An MOC process should be completed before implementing changes in:
- Processing chemicals and chemical handling procedures
- Changes in technology and control systems
- Changes to facilities, locations, and physical infrastructure
- Changes to company procedures, protocols, and operating practices
- Equipment changes including installation, modification, or replacement
PSM-MOC Requirements Under OSHA
The requirements a company or organization needs to comply with to meet the OSHA PSM standard for MOC are:
1. Identify the Proposed Change
Document what is being changed, why the change is needed, and which processes, equipment, or personnel are affected.
2. Assess Risk of Proposed Change
Conduct a thorough hazard analysis to identify potential safety, environmental, and operational risks associated with the change.
3. Classify Hazards and Risks
Categorize identified hazards by severity and likelihood to prioritize mitigation measures.
4. Evaluate Making the Change
Review whether the benefits of the change outweigh the risks, and determine what controls are needed to implement safely.
5. Implement the Change
Execute the change with all required safety controls, employee training, and updated operating procedures in place.
6. Pre-Startup Safety Review (PSSR)
Verify that construction meets design specifications, safety procedures are in place, training is complete, and process hazard analysis recommendations have been resolved before startup.
7. Monitor and Finalize
Track the change through the organization, verify it meets expectations, and update process safety information and operating procedures as needed.
Ecesis Management of Change Software
MOC Software
Streamline change reviews and approvals
Compliance Obligations
Track regulatory requirements and deadlines
Audits & Inspections
Schedule and conduct compliance audits
Incident Management
Report, investigate, and track incidents
Training Management
Track employee training and competency
Document Management
Centralized document storage and control
