In any facility governed by Process Safety Management (PSM) regulations, Management of Change (MOC) is not merely a procedural requirement—it serves as a frontline defense against operational risk. Yet, in many organizations that rely on Computerized Maintenance Management Systems (CMMS) to streamline maintenance and project workflows, gaps often emerge between operational execution and formal change control—gaps that are increasingly addressed through dedicated management of change software.
Are we treating safety as a prerequisite—or as a follow-up?
The Concern: MOC Becoming an Afterthought
In some facilities, initiating a project or generating a work order for an asset change or repair can occur before any formal safety review has been conducted. This can lead to situations where personnel, equipment, or contractors are mobilized before the organization has determined whether the change is safe to implement. When MOC becomes just another task in a checklist—completed after field work has begun or funding is allocated—the core intent of PSM is compromised.
What MOC Is Supposed to Do
MOC exists to evaluate the impact of changes—technical, procedural, organizational, or physical—before they are made. It is designed to ask one fundamental question:
Is this change safe, and have we identified and mitigated all associated risks?
Answering this question requires a structured, multidisciplinary evaluation before any execution begins. It is not simply about documenting change—it is about controlling risk at the point of decision-making.
What the Regulators and Experts Say
The U.S. Chemical Safety and Hazard Investigation Board (CSB) has repeatedly pointed to improperly managed change as a root cause in catastrophic incidents. Their guidance emphasizes that “managing change is essential to safe chemical process operations,” and that integrating MOC as a front-end requirement is critical to hazard prevention.
MOC Requires Robust Document Management
An often-overlooked aspect of effective MOC implementation is the need for robust electronic records and document management capabilities. MOC is not a one-time transaction—it is a lifecycle process that spans change initiation, risk assessment, review, approval, execution, pre-start-up safety review verification, and close-out. At each of these stages, the organization must capture and preserve evidence: engineering evaluations, safety reviews, approvals, mitigation plans, updated procedures, and close-out of all follow-up items.
This creates a rich and complex data set that must be maintained not only for internal review but also for external audits, incident investigations, and regulatory compliance. A true MOC system must provide full traceability, with version control, change histories, metadata tagging, and long-term retention.
In contrast, CMMS platforms are typically designed as transactional systems. Their primary function is to manage current state: open work orders, asset availability, costs, labor, and parts. While some CMMS platforms offer MOC “modules,” these are often limited in scope and do not provide the depth of records management and audit readiness that a robust MOC process demands.
The Right Tool for the Job
To meet both operational and compliance needs, MOC business processes should be supported by systems that are purpose-built for robust document and records management. These may include:
- Electronic Document Management Systems (EDMS) integrated with MOC lifecycles
- Regulatory-compliant audit trails and versioning
- Secure digital signature workflows
- Searchable repositories of historical MOC records for learning and legal defensibility
Pairing the transactional strengths of a CMMS with the information governance capabilities of an EDMS based MOC platform provides the complete framework needed to manage change safely, responsibly, and transparently.
Leadership Implications
For plant managers, HSE directors and executives, the challenge is not just in owning the MOC process—it’s in shaping the systems and culture that make safety the first gate, not the final formality.
To that end, organizations should:
- Enforce an MOC Procedure
Configure systems to prevent project or work order initiation until an MOC has been created and preliminarily reviewed. - Empower MOC Gatekeepers
Ensure that operations, engineering, safety, and environmental staff are trained and authorized to assess proposed changes before resource allocation. - Reinforce Accountability at the Top
Make it clear that safety and environmental risk are management’s responsibility, and that bypassing or delaying MOC is unacceptable—regardless of schedule pressure. - Audit and Monitor Compliance
Establish KPIs and dashboards that track MOC timeliness, completion quality, and pre-implementation adherence.
Closing Thought: No Change Is “Routine”
Every change—no matter how small—has the potential to introduce new risk. If your organization’s systems allow change to proceed without deliberate, documented analysis up front, that’s not just a system flaw—it’s a leadership gap.
The solution is clear: Ensure that your MOC program is not only integrated with your operational workflows but also supported by systems that preserve the full lifecycle of MOC documentation. Make safety the first decision—not the last checkbox.
