Management of Change (MOC)
Management of Change (MOC) provides a path forward for facilities contemplating and executing changes (excluding “replacement in kind”) to a process. The changes to a process requiring an MOC include any change in the process chemicals, technology, equipment, procedures, as well as any other modification affecting a covered process. The MOC program is comprised of written procedures that govern how the proposed changes will be managed by the facility. Per 40 CFR Part 68, the MOC documentation includes the following:
- The technical basis for the proposed change;
- Impact of change on safety and health;
- Modifications to operating procedures;
- Necessary time period for the change; and,
- Authorization requirements for the proposed change.
- Updates to the process Safety Information (if applicable).
The MOC process also requires that any employees involved in operating a process, including contract and maintenance personnel whose job tasks may be affected by the change, are made aware of the change and trained accordingly, prior to the restarting the process.