Management of Change (MOC)

Management of Change to facilities (commonly “MOC”) is an OSHA Process Safety Management regulatory requirement that applies to US companies managing hazardous materials and/or processes.


Gateway has developed a user-friendly, SharePoint solution for MOC that’s capable of creating, scoping, and managing the execution of change in an OSHA-compliant manner. It can be rapidly configured to follow an existing procedure and leverage SharePoint’s document management capabilities to deliver secure, enterprise-wide access to all the associated analytical data, drawings, documents and forms.

The MOC process can be decomposed into a number of states. The collection and sequence of states is termed the lifecycle. The essential difference between different kinds of MOC’s (e.g. permanent, temporary, emergency, etc.) is that they have different lifecycles. A lifecycle for a full, permanent MOC is shown below.

The diagram indicates that the lifecycle begins with the Initiation state. The MOC is “promoted” from one state to the next.
Initiation: The MOC is initiated by completing an electronic form. Typically this would cover a permanent, temporary or emergency change.

Scoping: The action items for an MOC are generated by completing electronic checklists, which are configured to meet each client’s specific requirements.

Role-specific Scoping: Different disciplines, e.g. environmental, safety, electrical, mechanical, may be called upon to conduct different scoping activities. This segmentation of scoping is supported by the application.

Management of Design Process: Proposed changes are normally documented in the form of redlines. The Gateway MOC application manages these work-in-process documents in SharePoint.

Impact Analysis: Various impacts are assessed during the MOC: process safety, environmental, financial, etc. These are supported by Gateway’s MOC application. The most common impact is the process safety impact which is addressed via a Process Hazards Analysis (PHA). Gateway’s MOC application triggers the proper resource to do the PHA at the appropriate time.

Management of PHA Follow-up Items: Most PHA applications output a list of follow-up action items that need to be addressed. Gateway’s MOC application has an action item import capability that permits the tracking and management of PHA follow-up items.

Reviews and Approvals: The MOC must be reviewed and approved according to certain rules. The specific persons doing the reviews and approvals are usually dependent on the location of the change. Gateway’s MOC application can handle all the commonly encountered ways of assigning reviewers and approvers.

Triggering Work Order Generation: When an MOC is approved, a notification is sent to Maintenance Planning to issue work orders. Upon completion of the work the MOC Owner registers it in the MOC application.

Implementation Activities: Most of the implementation activities take place in a facility. In addition to making the physical change, it’s important to do mechanical integrity inspections, and update operating procedures. This has to happen prior to training, and prior to Pre-Startup Safety Review (PSSR).

Detailed Training: Certain MOCs call for detailed, comprehensive training delivered in a classroom, on-the-job, or both. Analogous to how work orders are triggered by the MOC, when comprehensive training is needed, the MOC application notifies the Training department. Upon completion of the work the MOC Owner registers it in the MOC application.

Pre-Startup Safety Reviews and Operational Readiness Reviews: Are performed to validate that the change has been properly completed and the facility or equipment can be safely started up. Regulators expect that PSSR and ORR forms will be printed out, and completed at the job-site, by a person looking at the changed facilities. The Gateway MOC application triggers the appropriate resource to perform the PSSR/ORR and provides the PSSR/ORR form that can be printed and taken to the jobsite.

Authorization to Start-up: After the PSSR/ORR, the relevant manager provides the authorization to start-up and the MOC application captures this information.

Closing Out the MOC: The MOC is implemented using documents in the form of redlines. Redlines must be incorporated into the base documents once the MOC is closed out. This is triggered and managed by the MOC application.

Records Management: MOC records must be kept for many years. SharePoint is an outstanding platform for this purpose.

FACILEX® MOC Key Features:

Gateway’s FACILEX® MOC solution incorporates a complete package of industry best practices and is, by far, the most powerful yet easy-to-use solution on the market. It includes:

  • Lifecycle Support
    • The best practice is to use a lifecycle model (not workflow).
    • Any lifecycle can be configured,
    • Baseline configured with a lifecycles for permanent and temporary changes
  • Facility Structure Awareness
    • Your facility structure, e.g. areas, units, are configured to permit assigning action items to the proper personnel, and to provide better status reports, by unit.
  • Powerful, Flexible Scoping and Risk Ranking Capabilities
    • Common, and OSHA-required attributes on the MOC form
    • Your choice of additional attributes: text, numeric, date, boolean
    • Thorough MOC descriptions
    • Autonumbering: MOCs are automatically numbered, in almost any format, starting at any number the customer specifies
    • Each MOC has its own folder structure to store supporting documentation and work‑in‑process documentation
    • Any folder can contain any number of standard templates or forms
  • Exceptional Reporting Features
    • The baseline configuration comes with the following reports, each sorted and filtered by dates and units:
      • All Actions, by MOC
      • All Active Actions, by MOC
      • All Closed Actions, by MOC
      • All Overdue Tasks
      • All MOCs, by Location
      • All MOCs, by Status
      • All Open MOCs
      • All Overdue Temporary MOCs
    • Print out a comprehensive status on any open or closed MOC