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Many companies make changes to their processes on a regular basis for various reasons, such as improving yields, increasing production, reducing costs, etc. Changes to processes can lead to increased risk or produce new hazards, even apparently simple and straightforward changes. Hazards can be associated with process changes regardless of the size or complexity of the change or the process. Historically, numerous accidents have occurred as a result of changes for which the impact on process safety was not recognized.

Process changes should not be allowed to jeopardize process safety. A system to manage change can help prevent accidents. Changes to processes must be properly reviewed, approved, documented, and communicated to affected personnel prior to their implementation. Consideration of potential safety, health and environmental impacts is a vital part of the review and MOC is a vital part of process safety management.

Why Address MOC?

Management of change is required to ensures compliance with laws and regulations, for example, it is a required element of OSHA's PSM regulations. An MOC program is also needed to comply with industry codes, standards and recommended practices. It assists in controlling risks to the public, employees and the environment; minimizes business interruption; and helps to avoid property and product losses.

OSHA's current MOC requirements address only changes to process safety information, procedures, and facilities that affect a covered process. Replacements in kind (RIK), changes that satisfy the design specification, are not covered. Many other change types may impact process safety. In particular, the management of organizational change, such as personnel changes, is of particular importance.

Why Primatech?

Primatech has 24 years experience in helping companies design and implement process safety programs. We are experienced in helping companies develop and improve their MOC programs and we have conducted many audits of MOC programs. Primatech developed the enterprise software package, Tracker, to manage MOC tasks and track action items from all parts of a PSM program. Primatech also offers the training course, Management of Change (MOC) for Process Safety, as part of the Primatech Training Institute (PTI). Primatech can help you to ensure changes are reviewed properly and do not increase risk unacceptably.

Services Offered

  • Development of a new MOC program.

    We design an MOC program tailored to your specific needs and assist you with its implementation. We provide documentation of the program that integrates with the documentation of your other management systems.

  • Improvement of an existing MOC program.

    We review your current program and its implementation, make recommendations for improvements, and, if needed, work with you to implement the improvements. MOC program documentation is updated to reflect the modifications.

  • Assistance in the definition of the types of changes to be addressed.

    Many companies incorporate change types in addition to those required by regulations since industry practices have gone beyond the regulations. We help you to decide what change types should be addressed by your program. Your program documentation is updated to reflect the modifications.

  • Assistance with interfacing MOC with other facility programs.

    We help you to smooth out the interface of your MOC program with other PSM and non-PSM programs so that your management systems operate more smoothly. Program documentation is updated to reflect the modifications.

  • Tailoring an MOC program to work with a specific facility.

    We take your current program and work with you to make adjustments to tailor it to the facility. MOC program documentation is updated to reflect the modifications.

  • Auditing your current MOC program against regulatory requirements and/or industry best practices.

    We provide an audit report that identifies any needed corrective actions and, if needed, we can help you implement the corrective actions.

All Services