The OSHA Process Safety Management (PSM) regulation, 29 CFR 1910.119, is explicit in its intent to prevent catastrophic chemical releases. However, it does not clearly address how organizations should manage organizational changes—such as those involving personnel, reporting structures, or resource allocation. Section 1910.119(l) limits the Management of Change (MOC) requirement to changes in process chemicals, technology, equipment, procedures, and facilities that affect a covered process, leaving many organizations to rely on management of change solutions and applications to consistently capture, evaluate, and govern organizational impacts that fall outside the strict regulatory definition.
The CCPS Perspective
The Center for Chemical Process Safety (CCPS) has long recognized this gap. In its publication Guidelines for Managing Process Safety Risks During Organizational Change (2013), CCPS introduced the concept of Organizational Management of Change (OMOC) as a complementary discipline to technical MOC. The key message is simple: changes in people, structure, or responsibilities must be managed with the same rigor as physical or procedural modifications.
A well-defined OMOC process ensures that:
• Safety-critical roles remain filled and competent.
• Workload and supervision changes are assessed for risk.
• Training and handover requirements are completed before changes take effect.
• Documentation, access, and communication pathways remain intact.
Integrating organizational change into the MOC lifecycle transforms it from a compliance exercise into a holistic process safety management system—one that fully reflects the realities of modern, dynamic organizations.
Scoping the Change: The Foundation of an Effective OMOC
One of the most important and frequently overlooked steps in Organizational MOC (OMOC) is scoping the change—clearly defining what is changing, who is affected, and how risk should be evaluated.
FACILEX® provides three standard OMOC lifecycles, each designed for the type of organizational change being managed:
1. Organizational Structure Change – covering departmental realignments, reporting line adjustments, or the creation or removal of groups or functions.
2. Personnel Change – covering onboarding, transfers, terminations, retirements, or succession transitions.
3. Position Change – addressing role reassignments, promotions, or changes to responsibilities or authority levels.
Each lifecycle includes a comprehensive library of general and specific scoping checklists, aligned with CCPS guidelines, ensuring that all relevant considerations are identified before the change proceeds.
FACILEX® also includes a baseline OMOC Risk Matrix, which can be used immediately or replaced to incorporate the organization’s preferred risk matrix—ensuring alignment with existing corporate methodologies.
Document Security: A Critical Component of OMOC
Organizational changes often involve highly sensitive information. Promotions, hiring, onboarding, and retirements introduce continuous movement of confidential materials—resumes, performance reviews, competency assessments, and succession planning documents. These must be tightly controlled to protect privacy and maintain trust.
FACILEX® addresses this challenge through advanced document-level security configuration. Access permissions automatically align with role assignments and group memberships, ensuring that:
• Users can only view documents relevant to their responsibilities.
• Sensitive materials are isolated within secure SharePoint containers with complete audit trails.
• Confidential documents remain entirely invisible to unauthorized users—if you are not authorized to see it, you won’t even know it exists.
This zero-visibility model allows OMOC lifecycles to manage sensitive HR and organizational data within the same environment that governs process safety and engineering change—without compromising integrity or confidentiality.
Integration with HR Platforms: Connecting the Human Element
Because OMOC is always about people, not assets, integration with human resource systems is essential.
FACILEX® supports seamless connectivity through FACILEX CONNECT, enabling organizations to:
• Exchange personnel and position information securely with HR platforms such as SAP SuccessFactors®, Oracle® HCM, or Workday®.
• Automate population of change forms and reviewer assignments based on HR data.
• Store or retrieve confidential records in designated HR repositories while maintaining traceability in FACILEX®.
This integration ensures that organizational changes are synchronized with HR systems—reducing duplication, preserving confidentiality, and ensuring that every step of the change process is properly authorized and auditable.
FACILEX®: Turning CCPS Guidance into Operational Practice
FACILEX® transforms CCPS best practices into an integrated, auditable, and targeted lifecycles for managing both technical and organizational change. It enables companies to:
• Select from three standard OMOC lifecycles—Organizational Structure Change, Personnel Change, and Position Change.
• Apply CCPS-aligned scoping checklists and configurable OMOC risk matrices.
• Protect sensitive documents with zero-visibility security.
• Integrate seamlessly with enterprise HR systems through FACILEX CONNECT.
• Maintain full traceability and auditability throughout every stage of the change.
FACILEX® makes Organizational MOC practical, disciplined, and secure—bridging the gap between compliance and operational excellence.
Closing Thought
Regulations define the minimum. CCPS defines the standard of care. By extending Management of Change to include organizational and personnel changes, companies strengthen not only compliance but also continuity, culture, and control.
With FACILEX®, that standard is embedded in each MOC lifecycle—integrating technical and human change management under one intelligent, risk-based, and secure framework.
