What Is Management of Change?

Management of Change (MOC) is a systematic approach to dealing with organizational

change, typically in industrial facilities and operations. The goal of this approach is to
safeguard workers from potential harm during the crucial period of transition.

The Risk of Change

Numerous studies and historical data shows that the safety risks to workers during
change is many times higher than during routine production operations. Workforce
safety is one of the biggest concerns that go along with managing organizational
change.

A change to core processes, even temporary ones, can endanger the health and even
the lives of the workers. These risks are further magnified in companies dealing with
chemical substances and hazardous energy in their production system.

It’s critical to recognize and define change before introducing it to the process.

Addressing Change Risk with MOC

Without MOC, change can become more painful and challenging than it already is.
Sudden changes in procedure and workflow can cause confusion among workers and
contribute to process breakdowns.

A lack of familiarity with new processes and equipment can lead to accidents that
could impact the environment, lives, and property.

MOC forces organizational leaders to take a step back, analyze proposed changes and evaluate
all of the potential risks. This allows them to develop a systematic plan on how to prepare the
organization to reduce or prevent those hazards. In other words, MOC is a temporary safe
program for the organization.

To assess risk, engage a cross-functional team in a few hours of what-if brainstorming.

Do this early, while you’re still in the planning stage. Develop the definitions and
examples that apply to your situation and the risks your workers will be exposed to.

If risks can be reduced with a formalized change process, MOC will benefit your
organization.
When is MOC Needed?
As outlined above, it’s important to identify circumstances when Management of
Change must be applied. Below are some of the situations and applications when MOC
is needed.

Changes in Equipment Design

Whenever there is a change in the operational specifications of the equipment used

within a company, there is a greater danger for workers to make mistakes. Therefore, it’s
important to indicate the changes in equipment design (and specs) within the Process
Safety Information.

Changes in Operating Procedures

Each piece of equipment comes with step-by-step procedures on how to operate.

Furthermore, each aspect of work in a firm has systematic end-to-end procedures that
employees can simply follow and execute repeatedly.

Whenever operation guidelines or procedures are changed or updated by the company,

there is a risk for workers to continue with old processes because they are more used to
it.

Changes in Inspection and Test Maintenance Procedures

MOC is needed when a company’s way of inspecting and maintaining their equipment
changes. This ensures that employees don’t get exposed to chemically associated
hazards.

For example, procedures related to preventive maintenance of machines, an inspection

of piping, and servicing of equipment should be properly documented. Any changes to
these maintenance procedures must go through MOC.

Facilities Changes

MOC is also required whenever there are changes to the facilities themselves. For
example, when a new structure is built close to a PSM-covered piece of machinery, or if
it is modified in some way, MOC must be performed. Proximity to machines and
equipment can increase the risk of accidents.
Temporary Changes

Temporary events such as the examples below require MOC:

 Transfer of equipment to a temporary location due to infrastructure expansion

 Temporary procedure changes due to the installation of new equipment features

Even though these changes will not become a part of your standardized processes, it is
still important to be prepared for any negative impact they may have on the
organization, its facilities, and its people.

It is also critical for organizations to close out any MOC documentation of a temporary
change or to update the program if the temporary change becomes permanent.

Hazard recognition is the most important aspect of successful MOC implementation.

Rather than hyper-focusing on the changes themselves, your goal is to anticipate and
understand the hazards that will arise from change.

Likewise, all affected employees should be trained, equipped, and empowered to

expose hazards.

The Steps of MOC by Industry

Management of Change is a major component of a bigger process called Process Safety
Management (PSM). Compliance with PSM as a whole requires a thorough knowledge
of MOC best practices and steps.

You’ll notice that hazard recognition is the most important step in successful MOC
implementation. In this stage, the main focus is not on the actual changes that are
happening in the organization, but in anticipating and understanding the hazards that
will arise from such changes.

To do this, there must be a thorough review of things that could go wrong and how to
prevent those situations. There must also be a safety plan put into place if and when an
accident occurs.

It is essential therefore that a document control system and checklist of key steps to be
taken is utilised at all times from inception to completion (including any equipment
familiarisation and training) of any design change process in order to control the flow of
information and ensure that all changes are captured for the updating of records and
procedures etc both onshore and onboard.

The purpose of the Management Change Request is:

 To ensure that the documentation supporting a change includes a reason for the
change;

 To define the level of authority (minimum competence) required for approval of a

change;

 To Provide a clear understanding of the safety and environmental implications of a

change;

 To ensure that all changes comply with regulations, industry standards, good
seamanship practices and OEM design specifications;

 To include provision for issuing work permits before any work is carried out, or any
changes are made to the equipment;

 To ensure that potential consequences of a change are identified, together with

any mitigation measures, and that results are communicated to those affected by
the change;

 To ensure that changes not carried out within the proposed timescale are reviewed
and revalidated before they are completed;

 To identify any training needs arising from changes to equipment or procedures;

 To ensure that appropriate drawings, procedures and other technical documents

are updated following any change or modification;

 To ensure that the third party, working on our behalf, performs in a manner
compatible with our own policies and procedures. This would include both vessels
that are contracted in and personnel contracted to undertake maintenance,
inspections or repair work;

 To ensure provisions for entering of new vessel sand new types of vessels into
management.
8 Steps To Management of Change

Although the specific process of MOC may vary a bit for each industry (there are
different types of MOC), the general steps are pretty much the same.

Here’s the step by step rundown of what it takes to perform Management Of Change:

1. Recognize all changes. Without a thorough understanding of what changes are

going to happen, it is difficult for a management team to evaluate its potential impact
to the organization. Know the details of the change, so that it can be properly managed.

2. Identify the hazards and risks. A careful risk analysis must be done to cover every
potential hazard that the change will cause. Seemingly minimal effects should never be
overlooked. Instead, they should be treated as though they can impact the organization
in a big way. Worst-case scenarios for each risk must be identified, so that steps can be
made to avoid them.

3. Note hazards that can be minimized, controlled, or totally avoided. Management

needs to accept the reality that not all risks can be avoided. Some can only be managed
or reduced. It’s important to determine which risks can be totally avoided. Plans should
then be initiated to reduce or manage unavoidable hazards.

4. Find out if the change is feasible or can be implemented given the

circumstances. This is more like a risk-reward analysis. The management team can ask
themselves, “Can the changes be done with the least amount of danger possible, or do
the hazards caused by the change outweigh its rewards?”

5. Conduct a Pre-Startup Safety Review (PSSR). The PSSR is a thorough review of

equipment and its related processes to ensure that safety measures are in place. It is
most often used in processes involving chemical substances. This is more like a
verification check of the entire rocket ship before take-off (you get the picture).

6. Implement the change — if safe to do so. The organization must implement the
change, knowing all the risks in advance and how it might impact the workers. The goal
of responsible leadership must be to help employees smoothly glide through the painful
process of change without endangering them. Emergency measures should also be in
place if a potential accident turns into a real one.

7. Train all affected workers. Any involved employee, as well as all managers who will
execute your new processes, should be carefully trained on the new procedures. More
knowledge and hands-on-training will lead to fewer or zero instances of mishaps, or to
less serious consequences when failures occur.

8. Follow new procedures and continue to evaluate feedback from the ground. As
changes are rolled out, management should continue to evaluate the worker’s exposure
to risk. This can be receiving continuous feedback and reports from the organization’s
day-to-day operations.

Management Of Change does not mean that risk management is conducted only
during the change. The truth is, MOC happens long before a change is even
implemented.

Ideally, employers conducting MOC have already anticipated workforce safety issues
even before changes are introduced.

The above general steps may vary a bit depending on the type of MOC required. The
three most common types are administrative MOC, organizational MOC, and
technical MOC.

MOC Resources
The most valuable resources for MOC management are information/assistance provided
by your regulatory body, MOC checklists and forms, and safety management software.
MOC Forms

Your company’s change request process likely has an official form that allows you to
officially initiate and monitor the process.

MOC Checklists

Checklists allow you to facilitate and oversee your MOC plan.

You may want to build from past checklists used in your company or edit a checklist
template that will allow you to implement and monitor all the steps in your plan.