Management of Change (MOC) Software for Process Safety

What the regulations ask an MOC process to cover

In the United States, OSHA's process safety management standard, 29 CFR 1910.119(l), requires written procedures to manage changes to process chemicals, technology, equipment and procedures, and changes to facilities that affect a covered process. "Replacements in kind" are excluded, and the standard defines one as a replacement that satisfies the design specification, so the software should record who decided a change was like-for-like and against which specification.

Before any change, 1910.119(l)(2) requires the procedure to address five considerations: the technical basis, the impact on safety and health, modifications to operating procedures, the necessary time period for the change, and authorisation requirements. The time-period consideration is where temporary changes, their expiry and any extension belong. Paragraphs (l)(3) to (l)(5) then require affected operating, maintenance and contract employees to be informed and trained before start-up, and the process safety information and operating procedures to be updated when the change affects them.

Paragraph 1910.119(i) requires a pre-startup safety review (PSSR) for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. For a modified facility the review confirms, before highly hazardous chemicals are introduced, that construction and equipment match the design specifications, that safety, operating, maintenance and emergency procedures are in place and adequate, that the management of change requirements are met, and that operator training is complete.

Neither paragraph (l) nor Annex III of the Seveso III Directive describes an emergency or expedited MOC route. If your own procedure has one, the software should show how the (l)(2) considerations are still recorded, who authorised the shortened path and when the full review closes.

In the EU, the Seveso III Directive (2012/18/EU) lists management of change, meaning procedures for planning modifications to, or the design of, new installations, processes or storage facilities, among the issues the safety management system must address (Annex III, point (b)(iv)). Article 11 adds that a modification which could have significant consequences for major-accident hazards triggers a review, and where necessary an update, of the notification, the major-accident prevention policy (MAPP), the safety management system and the safety report, with the competent authority informed before the modification. In Great Britain the COMAH Regulations 2015 carry the same management-of-change item in Schedule 2, paragraph 2(d).

These are summaries for evaluating software, not legal advice. Whether a process is covered, and what your site's procedure must contain, is for your process-safety specialists to decide.

MOC evaluation checklist

Profiles documenting a management-of-change workflow

Ordered by how closely our sources document this process, not by quality. Sponsored placements are labelled. How lists are ordered

Same rule for every product: tagged “Management of Change”, with a sourced management-of-change capability in its record, or one the vendor stated to us, labelled as vendor-stated. 10 qualify; the first 8 are shown, then the other 2.

• Intelex

  The application separates evaluation, design/analysis, implementation and review. Test a location-restricted approver, an overdue temporary change and an incomplete PSSR; the published phase names alone do not establish those controls. Source: intelex.com

• Cority

  The product page describes risk screening and multi-step approval. In the demo, change the equipment specification after a reviewer signs and inspect which approval must be repeated; separately test temporary-change expiry and a PSSR gate. Source: cority.com

• ERA-EHS

  Its flow names pre/post-startup tasks and PSSR approval. Leave training incomplete and ask what blocks start-up. For the advertised offline approval, introduce a newer online revision before reconnection and inspect conflict handling. Source: era-environmental.com

• Evotix

  MOC is listed under Enterprise. Route a request by asset and location, leave an implementation action open and run the post-change review. Have the proposal name the product and module used in that demonstration. Source: evotix.com

• Safework Suite

  Documented: Management of change. Source: safeworksuite.com

• Sphera

  The page describes predefined workflows and central reviews. Start with a template, then test a site-specific exception and export its authorisation together with the original request and the post-change check. Source: sphera.com

• Optial

  The MOC page links risk and environmental impact to approval. Return one change for further assessment, revise its controls and show whether the old sign-off remains distinguishable from the new approval. Source: optial.com

• SMS360

  Documented: Actions, management of change, claims and document library (conditional). Source: sms360.com

A process-safety demo scenario

Use a temporary equipment substitution with an expiry date that changes an operating procedure and one P&ID, and affects a contract maintenance crew. Leave one hazard-review recommendation open and one PSSR item incomplete, then ask the vendor to attempt start-up. Next, let the temporary change reach its expiry and test both an extension and a reversal. Your specialists set the acceptance rules; the demonstration should prove how the configured workflow applies and records them.

Pricing: quote the MOC, PSSR and training scope

Quote the MOC application, approval roles, PSSR and training links, document links and any PHA or permit interfaces separately, and include workflow administration and upgrade review. Do not accept a general mobile feature as evidence that disconnected approval or start-up authorisation is supported.

Questions to include in your RFP