When a business modifies its procedures, operations, or facilities, it typically requires a Management of Change (MOC). While not applicable to all industries, it is specifically mandated for those following Process Safety Management (PSM) regulations. However, best practices for a PSM MOC advise that everyone use a written MOC risk assessment when changes are made.
Understanding MOC (Management of Change)
Management of Change (MOC) is a set of best practices used when a company makes changes that could expose or create hazards. While typically associated with industrial facilities, it is advised for all organizations to adopt MOC. Its overarching purpose is to safeguard workers from illness and injury during transitional phases, extending its relevance to all industries.
How Can MOC Benefit Your Company?
- Enhance Safety: MOC ensures a systematic approach to identifying and mitigating potential hazards, fostering a safer work environment.
- Keep Accurate Records: The MOC process mandates comprehensive documentation, promoting transparency, regulatory compliance, and informed decision-making.
- Better Communication: MOC requires clear communication of changes to all stakeholders, reducing misunderstandings and fostering a cooperative work environment.
- Boost Productivity: By identifying and mitigating potential challenges in advance, MOC promotes a smoother transition during changes, minimizing disruption and maintaining productivity.
- Reduce Risk: Rigorous risk assessments in the MOC process help identify and address potential risks, mitigating financial, operational, and safety risks for the company.
When Management of Change Programs Required?
A MOC is required when any of five certain elements change. If changes happen in these elements, a review is automatically initiated. There’s an exception if the company decides not to go through with the planned changes that would trigger the MOC process.
The five elements of MOC are:
- Processing chemicals
- Changes in the company’s technology
- Changes to the facilities
- Changes to company procedures
- Changes in equipment
Federal Agencies That Deal with MOC Compliance
Industries that handle specific chemicals must conduct a risk assessment. However, any business can initiate a MOC, even if it’s not mandatory. Two federal agencies oversee MOC compliance.
EPA
The Environmental Protection Agency (EPA) mainly watches over industries with a risk of chemical accidents. So, doing a MOC is important for the federal agency’s program to prevent chemical accidents.
OSHA
The Occupational Health and Safety Administration (OSHA) manages workplace safety compliance. By implementing Process Safety Management, the federal agency also works to oversee and eliminate any potential threats a chemical accident could cause. Companies that handle any of the listed 130 chemicals must have a PSM MOC any time changes are made.
8 Steps to a MOC Process
The Management of Change process involves eight key steps to ensure a systematic and safe approach to implementing changes in a workplace. The process might vary according to the industry, but the principle is the same.
1. Identify Proposed Changes
Know the proposed changes and how the business will be affected so they can be managed with minimal to no impact on the company.
2. MOC Risk Assessment
Conduct a thorough risk assessment to identify and evaluate potential hazards associated with the proposed change. Analyze the risks to determine the best mitigation strategies.
3. Determine if Hazards/Risks Can Be Controlled
Not all risks are preventable. Companies can only manage or minimize some. However, it’s not easy to classify risks, which is where the Hierarchy of Hazard Control can help. This classification method helps categorize hazards so you can create practical plans to minimize unavoidable risks.
4. Evaluate Making a Change
Determine if the change is cost-effective regarding cost, safety, hazards, and impact. Like risk analysis, management decides if the rewards outweigh the risks.
5. Implement Change If Safe
If the rewards are greater than the risks, start implementing the change. Employees must be aware of the changes, and management should be able to guide them smoothly through the transition. Employee safety is key, and companies should have the necessary backup emergency services and safety training in place.
6. Pre-Startup Safety Review (PSSR)
This step mainly applies to the chemical industry. A Pre-Startup Safety Review (PSSR) is required for all equipment and related practices. It verifies that all safety measures are implemented.
7. Train Workers on Change
All managers and employees affected by the implemented changes require training on the new processes and procedures. Hands-on training, as well as written reminders, will help prevent accidents. If you need expert help, our full-service safety management services can keep your workforce prepared.
8. Execute and Monitor Change
As the changes are implemented, management needs to continually monitor employee risks. Feedback from workers and reports from daily operations managers will help organizations know if their employees are exposed to potential hazards.
By following this Management of Change checklist, organizations can systematically manage changes, prioritize safety, and ensure a smooth transition in the workplace.
Safety By Design Can Help Prioritize Workplace Safety
Management of Change starts when a company decides to change its facilities, technology, equipment, procedures, or how it processes chemicals. It is a lengthy procedure with several time-consuming steps for companies with limited experience identifying the risks a change could bring.
As a top safety company in Houston, Safety By Design can check all your workplace risks. Our experts will examine everything when conducting a risk assessment for MOC — from ensuring trenches are safe during construction to considering what might happen if you change how chemicals are stored.
Contact a safety specialist today to see how we can help!
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