Implementing a Management of Change (MOC) system within a Process Safety Management (PSM) framework is a major undertaking. It’s a foundational element for managing risk, ensuring compliance, and maintaining the safe operation of complex industrial processes. However, one of the most overlooked yet essential success factors in any MOC project is effective scope management.
Start with the Core: Managing Asset Change
The primary goal of an MOC implementation should be to manage physical or operational changes to assets. These changes could involve equipment, instrumentation, process parameters, or operating conditions. Even with this focused objective, the effort is considerable.
To be successful, organizations should set their goals to implement their approved MOC procedure, using commercial, off-the-shelf software, on a reliable and secure electronic document management platform. This should include MOC lifecycles for Permanent, Temporary and Emergency asset changes at a minimum.
The project should also include data exchange mechanisms with existing platforms—typically Enterprise Resource Planning (ERP) systems or Computerized Maintenance Systems (CMS). These systems often contain critical information on asset history, maintenance records, and operational status. Exchanging information with these platforms involves analytical resources to determine what data is needed, how to capture it and how to keep it up to date.
The scope may also include closed or work in progress MOC projects. Consolidating MOCs onto one platform is ideal however it may require a significant investment in time and resources.
Beware of Scope Creep
Many organizations, concerned about choosing the ideal software platform, expand the scope of the MOC project to include change control for Quality Assurance and Process Safety Information (PSI)—such as P&IDs, operating procedures, safety data sheets, and control narratives. While this integration is eventually necessary for a mature PSM system, incorporating it into the initial MOC implementation will add several layers of complexity and cost.
These documents are typically siloed on separate platforms and controlled using different procedures and change management lifecycles. Integrating them with the MOC process requires coordination across engineering, operations, and document management teams. It could also expand the complexity and cost of any data migration initiative.
The same applies to integrating organizational change, critical defeats and safeguards into the initial MOC project. These business processes are managed with different lifecycles and exchange data with different platforms and databases.
Adopt a Phased Approach for Long-Term Success
The key to a successful MOC implementation is a phased and sustainable approach:
- Phase 1: Asset Change Management
- Deploy commercial MOC software on a reliable, secure EDM platform
- Implement lifecycles for Permanent, Temporary and Emergency changes
- Implement data exchange with key platforms and optional data loading
- Phase 2: Expand to QA and PSI
- Implement lifecycles for changes to Procedures and/or PSI
- Implement data exchange with key platforms and optional data loading
- Phase 3: Expand to Organization MOC, Critical Defeats and Safeguards
- Implement lifecycles for changes to organization, critical defeats and safeguards
- Implement data exchange with key platforms and optional data loading
Over time, organizations can build a robust, enterprise-wide MOC ecosystem using platforms like Microsoft SharePoint to support document control, workflow automation, and cross-platform integration. SharePoint’s capabilities—such as versioning, metadata tagging, and automated approvals—make it a strong foundation for scaling MOC beyond asset changes.
Conclusion
Trying to implement all aspects of MOC—asset changes, procedures, PSI, Organizational MOCs, critical defeats and safeguards—at once is rarely successful. It’s often too complex, too costly, and too overwhelming for most organizations to execute effectively.
By starting with core asset changes, establishing strong business processes, and scaling incrementally, organizations can deliver value quickly while laying the groundwork for a comprehensive, integrated, and sustainable MOC program. In the end, a disciplined approach to scope management is not just a project management best practice—it’s a critical enabler of long-term process safety success.
