Constructing a new facility that will use hazardous chemicals is a high stakes undertaking. From concept to commissioning, every decision carries implications for safety, regulatory compliance, schedule, and cost. In the United States, the use of hazardous substances automatically invokes stringent regulatory oversight, including OSHA’s Process Safety Management (PSM) Standard (29 CFR 1910.119). One of the most essential elements of PSM is Management of Change (MOC).
The Purpose of MOC in Construction
MOC is designed to ensure that any modification to a process—whether physical, procedural, or organizational—is evaluated, reviewed, and approved before implementation. While MOC is often associated with operating facilities, it is equally critical during construction, particularly when the design is evolving, procurement decisions are being made, and field adjustments are inevitable.
During construction, changes may include:
- Substituting equipment or materials due to supply chain delays
- Altering piping configurations in the field
- Updating control strategies based on new instrumentation
- Revising layout for access or egress
- Changing utility tie-ins or chemical delivery systems
Each of these changes can affect process safety, emergency response planning, or regulatory compliance. An effective MOC process ensures that these impacts are identified and mitigated.
Regulatory Context
If your facility will use hazardous chemicals above threshold quantities, OSHA’s PSM regulation mandates a formal MOC process for changes that affect:
- Technology
- Equipment
- Procedures
- Personnel responsibilities
The Environmental Protection Agency (EPA) also enforces the Risk Management Program (RMP), which aligns closely with PSM and shares its emphasis on rigorous change management. State and local authorities may have additional permitting or safety requirements tied to MOC outcomes.
Noncompliance, even during the construction phase, can result in:
- Regulatory citations and fines
- Project delays
- Forced redesigns
- Increased operational risk
MOC as a Risk Management Tool
MOC is not just a compliance exercise—it’s a risk management strategy. During construction, risk profiles can shift quickly. For example:
- Field routing of chemical transfer lines may create new leak or ignition sources.
- Equipment substitutions could introduce incompatibilities with corrosive materials.
- Changes to building structures may block egress or limit ventilation.
Each of these represents a deviation from the original Process Hazard Analysis (PHA) or design basis. By channeling changes through the MOC process, project teams can trigger hazard reviews, design verifications, and stakeholder communication—before changes are physically implemented.
Best Practices for Integrating MOC in Construction
- Start Early
Establish the MOC process before breaking ground. Integrate it with engineering change request workflows and contractor communication plans. - Define Triggers Clearly
Make it clear what constitutes a “change” and when the MOC process must be invoked. Tie it to deviations from P&IDs, equipment specifications, or safety-critical procedures. - Train Everyone
Ensure that project engineers, procurement teams, construction managers, and contractors are trained on the MOC process. Empower frontline staff to flag changes that may need evaluation. - Include Multidisciplinary Review
Each change should be reviewed by representatives from process safety, engineering, operations, and EHS. This ensures a full understanding of the impact. - Tie MOCs to PHA and Pre-Startup Safety Review (PSSR)
Update hazard analyses and ensure MOC items are closed out before commissioning. Every open MOC represents a potential blind spot. - Use a Centralized Tracking System
Implement digital tools to track MOC status, approvals, documentation, and closeout. This increases transparency and auditability.
Final Thoughts
Too often, MOC is treated as a post-startup concern—but by then, unsafe or non-compliant decisions may already be built in. A proactive and disciplined MOC process during construction protects workers, ensures regulatory compliance, and reduces costly rework.
If the new facility that will use more than a Threshold Quantity (TQ) of any hazardous chemicals, build MOC into the foundation of your project management practices—not just your process safety program.
Need Support?
If you’re building or expanding a PSM covered facility, Gateway can help you implement a fully integrated MOC solution tailored to your project’s needs. Contact us for information on licensing the FACILEX® PSM suite for your engineering and construction projects.
