Implement Management of Change: PSM Element 10 Checklist
Implement Management of Change: PSM Element 10 Checklist
Author: Fidelis Associates | Published: 2026-03-03 | Last Updated: 2026-03-03
Meta Description: Checklist for OSHA 1910.119(l) Management of Change — verify MOC procedures, technical evaluation, authorization, training, and close-out requirements.
OSHA Reference
Under OSHA's Process Safety Management standard 29 CFR 1910.119(l), employers must establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures. Prior to any change, the following must be addressed: the technical basis for the proposed change; impact of change on safety and health; modifications to operating procedures; necessary time period for the change; and authorization requirements for the proposed change. Employees involved in operating the process and maintenance and contract employees whose job tasks will be affected must be informed of, and trained in, the change prior to startup.
Fidelis Insight
Management of Change is the element that keeps a PSM program current. Every facility changes over time — equipment is modified, chemicals are substituted, operating conditions are adjusted, procedures are revised. MOC ensures that each change is evaluated for its safety implications before it is implemented, and that the downstream effects on procedures, training, PSI, and PHA are addressed.
The most common MOC failures fall into three categories: changes that bypass the MOC process entirely (often because the boundary between MOC and replacement-in-kind is poorly defined), temporary changes that become permanent without completing the MOC lifecycle, and incomplete close-out where the change is implemented but procedures, training, and documentation are not updated.
Strong MOC programs define clear triggers for when MOC is required, ensure that evaluations are technically rigorous and not just administrative approvals, and close out every change completely — including PSSR if required, procedure updates, training, and PSI updates.
Common Gaps We See
- ⚠ Boundary between MOC and replacement-in-kind poorly defined — changes bypass MOC
- ⚠ Temporary changes become permanent without completing the MOC lifecycle
- ⚠ MOC close-out incomplete — change implemented but procedures, training, and PSI not updated
- ⚠ MOC evaluations are administrative approvals rather than technical safety evaluations
- ⚠ Training on changes not completed before startup
- ⚠ No formal tracking system for open MOCs and close-out status
- ⚠ Organizational and procedural changes not recognized as MOC triggers
- ⚠ PSSR not triggered when MOC requires changes to process safety information
Best Practices Checklist
MOC Procedures
- [ ] Written MOC procedures cover changes to process chemicals, technology, equipment, and procedures
- [ ] Clear criteria define what constitutes a change vs. replacement-in-kind
- [ ] Organizational and staffing changes evaluated for PSM impact
- [ ] Procedure changes managed through the MOC process
Technical Evaluation
- [ ] Technical basis for the proposed change documented
- [ ] Impact on safety and health evaluated by qualified personnel
- [ ] Modifications to operating procedures identified and planned
- [ ] Impact on PHA and PSI assessed
- [ ] Necessary time period for the change established (especially for temporary changes)
Authorization & Training
- [ ] Authorization requirements defined and followed for each change
- [ ] Employees informed of and trained on the change prior to startup
- [ ] Contract employees whose tasks are affected informed and trained
- [ ] Training documented with completion dates and competency verification
Close-Out & Follow-Through
- [ ] PSSR conducted when the change requires modification to process safety information
- [ ] Operating procedures updated to reflect the change
- [ ] Process safety information updated (P&IDs, equipment data, safe operating limits)
- [ ] PHA updated or noted for next revalidation
- [ ] Temporary changes tracked with defined time limits and formal close-out
- [ ] MOC close-out verified and documented before the change is considered complete
Scoring Tip
- 16–19 checks = Strong MOC program
- 9–15 checks = Needs improvement
- 0–8 checks = Immediate action required
Practical Use
Use this checklist to evaluate your MOC process from initiation through close-out. Pay particular attention to the boundary between MOC and replacement-in-kind — if your facility cannot clearly define and document this distinction, changes may be bypassing the MOC process. Review temporary changes quarterly to ensure they are either closed out or formally converted through the full MOC process.
Key Takeaways
- MOC applies to changes in chemicals, technology, equipment, and procedures — not just physical modifications.
- The replacement-in-kind boundary must be clearly defined and documented.
- Temporary changes must have defined time limits and formal close-out — they cannot become permanent by default.
- MOC close-out is where most programs fail — the change is made, but procedures, training, and PSI are not updated.
- Training on changes must be completed before startup, not after.
Assess Your Program
Use this checklist as a starting point, then benchmark your program with a FidelisCheck PSM assessment.
Related Resources
- What is Process Safety Management? A Complete Guide
- The 14 Elements of PSM: A Practitioner's Breakdown
- OSHA 1910.119 PSM Compliance Checklist
- Management of Change (MOC): Best Practices for Industrial Operations
- PSM Element 7: Pre-Startup Safety Review (PSSR) Checklist
Frequently Asked Questions
What triggers a Management of Change review under OSHA PSM? Under 29 CFR 1910.119(l), MOC procedures are required for changes to process chemicals, technology, equipment, and procedures — excluding replacements in kind. The key question is whether the proposed change could affect process safety information, operating procedures, or the basis of the existing process hazard analysis. Changes to staffing levels, shift structures, and safety-critical roles should also be evaluated through MOC, although this is a best practice frequently overlooked. If there is any doubt about whether a change qualifies, the safer approach is to process it through MOC.
What qualifies as replacement-in-kind under MOC? Replacement-in-kind means substituting equipment or components with items that meet the original design specifications in all respects — same materials of construction, same capacity, same design pressure and temperature, same control configuration. If any specification differs from the original design, the replacement is not "in kind" and requires MOC evaluation. Common misclassifications include replacing a carbon steel component with stainless steel, substituting a gasket with a different material, or installing a relief valve with a different set pressure. The replacement-in-kind determination must be documented, and facilities should maintain clear criteria so that the boundary is applied consistently.
How long should MOC documentation be retained? OSHA 1910.119(l) does not specify a retention period for MOC records. However, best practice is to retain MOC documentation for the life of the process or at least until the next PHA revalidation cycle (every five years per 1910.119(e)). PHA teams need access to MOC history to evaluate cumulative changes and verify that process safety information reflects the current process configuration. Many facilities retain MOC records indefinitely as part of their process safety information management system.
Fidelis Associates provides PSM compliance consulting and assessment services through FidelisCore and FidelisGap. Our team brings 40+ years of combined experience across major operators including Chevron, Valero, and Shell.
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