Management of Change (MOC) is the gatekeeper that prevents uncontrolled modifications from introducing new hazards into your covered processes. Under 29 CFR 1910.119(l), employers must establish written procedures to manage changes to process chemicals, technology, equipment, procedures, and facilities that affect a covered process. MOC is one of the most frequently cited PSM elements because changes happen continuously and each one has the potential to invalidate existing safeguards. Ecesis provides dedicated MOC software with customizable workflows, impact assessments, and complete audit trails.
What OSHA Requires
Under 29 CFR 1910.119(l), employers must establish and implement written procedures to manage changes (except replacements in kind) to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process. Procedures must 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
- Authorization requirements for the proposed change
Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change must be informed of, and trained in, the change prior to startup. If a change results in a change to process safety information, that information must be updated accordingly. If a change results in a change to operating procedures or practices, those must be updated as well.
Step-by-Step Implementation
Define What Constitutes a Change
The most important step in MOC implementation is clearly defining what requires an MOC versus what qualifies as a replacement in kind. Develop written criteria that address:
- Changes requiring MOC: Different materials of construction, different operating conditions, different process chemicals, different equipment specifications, modified control logic, altered operating procedures, changes to safety systems
- Replacements in kind (no MOC required): Replacing equipment with identical specifications (same manufacturer, model, materials, rating). Document that the replacement meets all original design specifications
- Gray areas: Equipment that is functionally equivalent but from a different manufacturer, procedure changes that do not affect safe operating limits, temporary modifications. Define how these will be evaluated
Train operations and maintenance personnel to recognize when an MOC is needed.
Design the MOC Workflow
Build a structured workflow that ensures every change is properly evaluated and authorized before implementation:
- Initiation: Anyone can submit a change request describing the proposed change and its purpose
- Technical review: Evaluate the technical basis, impact on safety and health, and modifications needed to PSI, procedures, and training
- Authorization: Appropriate level of management approval based on the risk and scope of the change
- Implementation: Execute the change per the approved plan, update documentation, and conduct training
- PSSR: Perform pre-startup safety review before operating under new conditions
- Closeout: Verify all action items are complete, documentation is updated, and training is documented
Integrate with Other PSM Elements
MOC does not exist in isolation. Each change can trigger requirements across multiple PSM elements:
- Process safety information: Update P&IDs, equipment specifications, and chemical data as needed
- Operating procedures: Revise procedures affected by the change
- Training: Train affected employees before startup
- PHA: Consider whether the change warrants a PHA update or a focused hazard review
- Mechanical integrity: Add new equipment to the inspection schedule
- PSSR: Conduct review before operating under modified conditions
Build these integration points into your MOC form and workflow so they cannot be overlooked.
Manage Temporary Changes
Temporary changes present unique risks because they are often treated with less rigor than permanent changes but can exist for extended periods. Establish clear procedures for temporary changes that include:
- Maximum duration allowed before the change must be made permanent or reversed
- The same review and authorization process as permanent changes
- A tracking mechanism that ensures temporary changes are reversed at the end of the authorized period
- Evaluation of whether the temporary change needs its own PHA review
Common Pitfalls to Avoid
How Software Supports This Element
Ecesis provides purpose-built management of change software designed for PSM compliance:
- Customizable workflows: Define your review, approval, and closeout stages with automatic routing to the right reviewers
- Impact assessment forms: Built-in checklists ensure every MOC evaluates impacts on PSI, procedures, training, PHAs, and mechanical integrity
- PSSR integration: PSSR checklists are automatically triggered within the MOC workflow
- Temporary change tracking: Automated expiration tracking and notifications prevent temporary changes from becoming permanent by default
- Complete audit trail: Every action, approval, and modification is logged with timestamps for audit readiness
Frequently Asked Questions
What is a replacement in kind?
A replacement in kind is a replacement that satisfies the original design specification. For example, replacing a valve with an identical valve from the same manufacturer with the same pressure rating, materials of construction, and size. If any specification changes, it is not a replacement in kind and requires MOC review.
Do procedure changes require MOC?
Changes to operating procedures that affect how a covered process is operated should go through MOC. Minor editorial corrections or formatting changes that do not alter the substantive content or safe operating parameters typically do not. Your MOC procedure should define the threshold.
How do we handle emergency changes?
Establish an emergency change procedure that allows immediate action to address imminent hazards while still capturing the change in the MOC system as soon as practical. The emergency MOC should be reviewed and formally processed within a defined timeframe (typically 24 to 72 hours).
Who should approve MOCs?
OSHA does not specify approval authority, but the approver should have the technical knowledge and organizational authority appropriate to the scope and risk of the change. Many facilities define tiered approval levels based on the risk assessment of the change.
How long should MOC records be retained?
OSHA does not specify retention periods for MOC records. Best practice is to retain MOCs for the life of the process or equipment involved, as they become important references during PHA revalidations, incident investigations, and compliance audits.
Ecesis PSM Compliance Software
PSM Software
Centralized platform to manage all 14 PSM compliance elements
Management of Change
Submit, route, and approve change requests through defined workflows
Incident Investigation
Report, investigate, and track corrective actions to completion
Training Management
Deliver and track PSM training with comprehension verification
Mechanical Integrity
Schedule inspections, track deficiencies, and manage maintenance
PSM Compliance Calendar
Track deadlines across all 14 elements automatically
