Reinventing Management of Change: Lessons from 30 Years of Digital Process Safety – Part 3
Executive Summary
For process safety engineers and plant managers, Management of Change (MOC) is not an abstract concept—it is a daily operational reality. Every modification to equipment, procedures, materials, staffing, or control systems carries potential risk.
Yet many organizations underestimate the most consequential decision they make about MOC: the architecture of the digital system that supports it.
Most MOC platforms fall into one of two categories:
- Fixed-process systems, where the structure of MOC is predefined and difficult to modify
- Configurable lifecycle systems, where the process adapts to the technical and operational context of each change
This distinction is not merely technical. It directly affects how effectively organizations identify hazards, manage risk, and sustain operational discipline.
For engineers and plant managers, the question is not which system is easier to deploy, but which system reflects the realities of industrial change.
Fixed-Process MOC Systems: Predictable but Constrained
Fixed-process Management of Change systems are designed around standardized workflows. They are attractive because they promise consistency, simplicity, and rapid deployment.
From an operational perspective, fixed systems offer:
- Clear procedural steps
- Standardized approval pathways
- Uniform documentation requirements
- Simplified training for users
However, these advantages come at a cost.
Industrial change is rarely uniform. Fixed systems struggle to accommodate variations in:
- Technical complexity
- Risk profile
- Regulatory requirements
- Organizational structure
- Facility-specific practices
As a result, engineers and plant teams often encounter situations where the system does not reflect the actual work required to manage a change safely.
When this happens, organizations typically respond in one of three ways:
- They force complex changes into simplified workflows.
- They create workarounds outside the system.
- They abandon the system for certain categories of change.
Each response erodes the integrity of the MOC process.
Configurable Lifecycle MOC Systems: Adaptable but Disciplined
Configurable lifecycle systems take a fundamentally different approach. Rather than prescribing a single process, they provide a framework within which MOC requirements can be tailored to the nature of the change.
For process safety engineers, this means:
- Risk-based scoping of MOC requirements
- Conditional triggers for PHA, PSSR, and other analyses
- Dynamic assignment of roles and responsibilities
- Facility-specific governance models
For plant managers, it means:
- Greater alignment between MOC processes and operational realities
- Improved visibility into change-related risk
- More credible audit trails
- Reduced reliance on informal processes
Critically, configurability does not imply a lack of discipline. It enables discipline to be applied intelligently, rather than uniformly.
Practical Implications for Process Safety and Operations
The architectural choice between fixed and configurable systems has tangible consequences in day-to-day operations.
1. Scoping of Change
In fixed systems, scoping is often superficial because the system does not provide mechanisms to differentiate between types of change.
In configurable systems, scoping becomes a structured exercise informed by risk, impact, and context.
2. Integration with Engineering and Operations
Fixed systems often operate as standalone tools. Integration with engineering documentation, asset data, and operational systems is limited or manual.
Configurable lifecycle systems are designed to maintain relationships between changes and the technical artifacts they affect.
3. Consistency Across Facilities
Fixed systems enforce uniformity but struggle to accommodate site-specific practices.
Configurable systems enable standardization at the enterprise level while allowing controlled variation at the facility level.
4. Sustainability of the MOC Program
Over time, fixed systems tend to accumulate exceptions and workarounds, leading to process drift.
Configurable systems are inherently more resilient because they evolve with organizational and technical complexity.
The Hidden Risk of Fixed-Process MOC
From a process safety perspective, the most significant risk of fixed-process MOC systems is not inefficiency—it is false confidence.
When systems appear structured and compliant but fail to capture the nuances of change, organizations may believe they are managing risk effectively when they are not.
For plant managers, this manifests as:
- MOC metrics that look strong but lack substantive meaning
- Audit findings that reveal systemic gaps
- Incidents that trace back to poorly scoped changes
For process safety engineers, it manifests as:
- Repetitive rework
- Inconsistent hazard identification
- Difficulty linking changes to historical risk data
These are not software problems. They are architectural consequences.
Architecture as a Strategic Decision
The design of an MOC system should not be delegated solely to IT departments or vendors. It is a strategic decision that shapes how organizations perceive, evaluate, and manage change.
For process safety engineers and plant managers, the key questions are:
- Does the system reflect the complexity of real-world change?
- Can it differentiate between routine and high-risk modifications?
- Does it integrate with the broader PSM ecosystem?
- Does it preserve institutional knowledge over time?
If the answer to these questions is no, the organization is not managing change—it is managing paperwork.
Looking Ahead: Integration as the Next Frontier
In Part 4 of this series, Why Management of Change Cannot Operate in Isolation from the PSM Ecosystem, we will examine why MOC cannot operate in isolation from other process safety elements and how integrated digital architectures are reshaping risk-based process safety.
