So, what is management of change (MOC)?
Going back to the source, OSHA 1910.119(l)(1) sets the requirements for MOC as: “The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment and procedures; and, changes to facilities that affect a covered process.”
Here are some bad excuses for not following an MOC process which leads to process safety incidents.
• But I am not making a real modification. I am just making it a little better.
• I am so far behind I can’t start doing MOC. I’ll never catch up with all of those unrevised drawings.”
• I don’t have time to wait for the MOC evaluation. This is an emergency!
• Routing this form for approval takes so long we can never get anything done.
• But my area manager already has to approve funds for changes.
• We are a warehouse / light manufacturing / data center / repair facility. … We don’t have anything that could be dangerous.
• But MOC won’t catch every possible problem, so why do it?
• This is just a software/procedure change. It’s not like we were changing a pipe or something. We don’t need to approve or document.