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.
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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
What OSHA 29 CFR 1910.119(l) Requires
The Management of Change element of the PSM standard is codified at 29 CFR 1910.119(l). It requires employers to establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process. The one explicit exception is a replacement in kind (explained below).
Under 1910.119(l)(2), those written procedures must address all of the following before a change is made:
- The technical basis for the proposed change
- Impact of the change on safety and health
- Modifications to operating procedures
- The necessary time period for the change
- Authorization requirements for the proposed change
Three further provisions complete the requirement. Under 1910.119(l)(3), employees who operate a process — and maintenance and contract employees whose tasks are affected — must be informed of and trained in the change before start-up. Under 1910.119(l)(4) and (l)(5), if a change alters the process safety information required by paragraph (d) or the operating procedures required by paragraph (f), those documents must be updated accordingly.
Replacement in Kind vs. a Change
A replacement in kind (RIK) is a replacement that satisfies the design specification of the item being replaced — for example, installing an identical pump with the same specifications. A true RIK does not trigger MOC. Anything that deviates from the original design specification — a different material of construction, a higher-capacity motor, a substitute chemical, a revised set point — is a change and must go through the MOC process. Because this boundary is where many PSM citations originate, a strong program makes the "is this a replacement in kind?" determination explicit and documented rather than left to individual judgment.
The PSM-MOC Process, Step by Step
Turning those regulatory requirements into a working routine, a compliant PSM-MOC workflow generally follows these steps:
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.
How PSM MOC Connects to Other PSM Elements
MOC is the hub that keeps the other PSM elements accurate as a facility evolves:
Process Safety Information (PSI — 1910.119(d))
When a change alters chemical data, technology, or equipment, the PSI — P&IDs, relief-system design, materials of construction, and safe operating limits — must be updated so it always reflects the current process.
Process Hazard Analysis (PHA — 1910.119(e))
Significant changes often require revisiting the PHA to evaluate hazards the original study did not consider.
Operating Procedures & Training (1910.119(f), (g))
Changes that affect how a process is run require updated operating procedures and worker training before start-up, as required by 1910.119(l)(3) and (l)(5).
Pre-Startup Safety Review (PSSR — 1910.119(i))
For new and modified facilities, a PSSR confirms the change is safe to start: construction meets design, procedures are in place, training is complete, and PHA recommendations are resolved. See MOC vs PSSR.
Temporary Changes Under PSM
OSHA does not exempt temporary changes from MOC. In fact, 1910.119(l)(2)(iv) specifically requires the procedures to address the necessary time period for a change — aimed squarely at temporary modifications. Temporary changes must be reviewed and authorized like any other change, given a defined expiration, and formally closed out or converted to a permanent change before that period lapses. Temporary changes that quietly become permanent — a bypassed interlock, a jumpered alarm — are a well-documented cause of process-safety incidents. See types of management of change for how temporary, permanent, and emergency changes differ.
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
Frequently Asked Questions
What is Process Safety Management (PSM)?
Process Safety Management is an OSHA standard (29 CFR 1910.119) that requires employers who handle highly hazardous chemicals to identify, evaluate, and control process hazards. It has 14 required elements, one of which is Management of Change.
How does Management of Change relate to PSM?
Management of Change is one of the 14 required PSM elements. It ensures that changes to chemicals, technology, equipment, procedures, and facilities are reviewed for safety and health impact, authorized, documented, and communicated before they are implemented.
What does 29 CFR 1910.119(l) require for MOC?
Employers must have written procedures that, before any change, address the technical basis for the change, the impact on safety and health, modifications to operating procedures, the necessary time period, and authorization requirements. Affected employees must be trained before start-up, and process safety information and operating procedures must be updated.
What is a replacement in kind under PSM?
A replacement in kind is a replacement that meets the design specification of the item being replaced, such as an identical pump. It does not trigger Management of Change. Any deviation from the original design specification is a change and must go through the MOC process.
What five things must a PSM MOC address?
Under 1910.119(l)(2): the technical basis for the change, the impact on safety and health, modifications to operating procedures, the necessary time period for the change, and authorization requirements.
What is a Pre-Startup Safety Review (PSSR)?
A Pre-Startup Safety Review, required by 1910.119(i), is performed before starting a new or modified process. It confirms that construction meets design specifications, safety and operating procedures are in place, training is complete, and process hazard analysis recommendations have been resolved.
Does OSHA PSM require MOC for organizational or staffing changes?
The standard addresses changes to process chemicals, technology, equipment, procedures, and facilities. OSHA guidance and industry best practice treat organizational or staffing changes that can affect process safety as changes that should be evaluated through MOC, and many facilities include them in their program.
How can MOC software help with PSM compliance?
MOC software enforces the written procedure OSHA requires, routes changes through the mandatory reviews and authorizations, links changes to process safety information, hazard analyses, and pre-startup reviews, tracks temporary-change expirations, and maintains the complete time-stamped audit trail inspectors expect.
