How do I recognize a “change” for an MOC?

How do I recognize a “change” for an MOC?
UPDATED: DECEMBER 2021

Management of Change (MOC) is an essential work process designed to evaluate changes in industrial facilities.  This process keeps employees safe, lengthens asset reliability, and keeps sites in compliance with industry regulations. 

To kickstart an MOC, a team member must first recognize a proposed modification qualifies as a change. 

It sounds simple enough, but is it? 

 “The most difficult part of Management of Change is recognizing change.”  
- Sam McNair, P.E., CMRP 

Uncontrolled changes (those not managed with an MOC) regularly occur around the plant and create a serious risk to the facility and its members. These changes are not created maliciously.  Oftentimes, teams may not think of their plans or modifications as an MOC-required change. 

With the industry’s continuously evolving definition of “change,” it is easy to imagine why. 


What makes up an MOC-required change?  

To identify what makes up an MOC-required change, we can broadly interpret OSHA’s definition as:

Any change to a plant’s 5 elements except when it’s a replaced in kind that affects a covered process.

There are a few qualifiers in the definition, so we will break them down one by one.  

OSHA Diagram | Management of Organizational Change

“Any change...” 

There are certain types of changes (beyond the obvious) to look out for when considering what constitutes an MOC.  These include temporary changes, emergency changes, organizational changes, and small changes.

• Temporary changes require MOCs no matter how short the team plans for the change to remain in effect. Although they sound benign, they can be even riskier than permanent changes.  Since they are considered temporary, some may have less robust designs, which adds even more risk when the change remains in place longer than anticipated.  (And as we like to say, "The only permanent change is a temporary change.")
  
  
• Emergency changes occur when an issue demands a short planning and execution window.  These changes are usually for imminent risks such as personnel injury, environmental incidents, and equipment damage. Although a disciplined, well-established MOC might seem time-consuming, they are crucial in preventing even more harm than the original issue.
  
  
• Organizational change – Beyond OSHA’s five elements, an MOC is also required for changes to a facility’s organization, staffing, and policies that could reasonably expect to result in changes that can affect the five elements.
  
  
• Small changes – Finally, sometimes it’s the little things. It could be a seemingly harmless routine maintenance activity performed with slightly different procedures that creates an uncontrolled change.  Just as great care goes into large projects and changes, small changes also need attentive design and evaluation. 

 
“…to a plant’s 5 elements…” 

A plant's five elements are Process chemicals, Technology, Equipment, Procedures, and Facilities. 

“…except when it’s replaced in kind…”  

The notable exceptions to any change to a plant’s five elements are those deemed a replacement in kind (RIK).  RIKs are replacement plans that satisfy the original design specification.  These situations do not require an MOC. 

Though this seems intuitive, the RIK exception definition is ambiguous and open to interpretation in many cases.  Ambiguity becomes problematic when RIK changes build up over time, RIK qualifications are unclear, or limited due diligence takes place to see whether a change truly satisfies an RIK designation. 

One example is when a manufacturer replaces a valve with a different brand or model.  While this may seem to qualify as a simple RIK, the team still should perform diligence on design specifications (including a review of materials of construction, pressure, temperature, and flow ratings, mode of operation, etc.).  Even if the specifications are satisfactory, other factors (such as changes to mechanical integrity documentation) may still require an MOC. 

"…that affect a covered process.” 

Finally, MOCs are required if when they affect a covered process.   

OSHA defines a covered process as any activity involving a highly hazardous chemical (HHC) including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or a combination of these activities.

However, systems that do not contain HHC may still be considered a covered process.   

Recently, OSHA standards have expanded the definition to include non-HHC systems that may consequentially affect an HHC release.  For example, if a steam system can overpressure a downstream vessel containing HHC, then OSHA's process safety management requirements may apply to this steam system, including MOC. 

So, what should the rule of thumb be? 

If you’re unclear whether an MOC is needed, err on the side of caution.  

Plan as if you need to start the MOC process while requesting additional guidance from teammates and supervisors.  Oftentimes, a company will have established MOC procedures that include a defined scope of what constitutes an MOC.  Make sure you use that as a helpful resource! 

Even if a change is considered an exception to the MOC process, it is best practice to be cognizant of how changes may affect the safety of the process and those around you.  Doing so will identify and mitigate hazards before they occur.