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    All templatesCompliance · 2 pages · Updated 25 September 2026

    Management of Change (MOC) Template

    Two-page MOC form: change description and type, pre- and post-change risk scores, a five-function approval, training and communication, an implementation plan, verification at 30, 90 and 180 days, and closure. Its considerations follow 29 CFR 1910.119(l); what the PSM rule needs that the form does not name is listed below.

    What's Inside

    1. Change description — MOC reference number, requestor, date raised, change type (temporary, permanent, emergency), scope (what and why)
    2. Risk evaluation — likelihood, severity, score and "acceptable?" before and after the change
    3. Stakeholder review and approval — operations, EHS, engineering, maintenance and the operations manager, each approving or rejecting with a date
    4. Training and communication — audience, method, owner
    5. Implementation plan — phase, activity, owner, start, finish
    6. Verification — at 30, 90 and 180 days, with verifier and date
    7. Closure — lessons learned, closed by, date closed

    What requires or shapes this record

    Management of change is a named requirement in two US process safety rules, with almost identical wording, and a clause of ISO 45001. The US text is short enough to map field by field.

    • 29 CFR 1910.119(l)(1)–(l)(5)

      Written procedures must manage changes, except replacements in kind, to process chemicals, technology, equipment and procedures, and changes to facilities that affect a covered process. Before any change they must address (i) the technical basis, (ii) the impact on safety and health, (iii) modifications to operating procedures, (iv) the necessary time period and (v) authorization requirements. Paragraph (l)(3) requires affected operating, maintenance and contract employees to be informed and trained before start-up; (l)(4) and (l)(5) require the process safety information and operating procedures to be updated.

    • 29 CFR 1910.119(i)

      A pre-startup safety review is required for a modified facility when the modification is significant enough to change the process safety information. It confirms construction to design specifications, adequate procedures, that the management of change requirements are met and that operator training is complete.

    • 40 CFR 68.75(a)–(e)

      EPA's Risk Management Program rule repeats the same five considerations, the training-before-start-up rule and the two update duties, with "stationary sources" in place of "facilities".

    • ISO 45001:2018, clause 8.1.3

      Outside PSM-covered processes, clause 8.1.3 (management of change) is the requirement this record evidences in a certified system.

    Each source checked on 25 September 2026. Not legal advice; check the text in force for your site.

    Field by field

    The form has no dedicated fields for (l)(2)(iii) procedure changes, (l)(2)(iv) the time period, or the (l)(4) and (l)(5) updates. Write them as rows of the implementation plan, as in the example below, so that closure cannot happen without them.

    MOC reference #
    Why: Ties the change to its pre-startup review, permits and marked-up drawings.
    Common mistake: Raising the number after the work is done, a retrospective MOC that nobody reviewed before the change.
    Change type: temporary, permanent, emergency
    Why: A temporary change needs an end date and a check that the plant went back.
    Common mistake: Treating "emergency" as an exemption. Paragraph (l)(2) says "prior to any change" and (l)(1) exempts only replacements in kind, so an expedited route still records each consideration and who authorized it.
    Scope (what / why)
    Why: Carries the technical basis, (l)(2)(i).
    Common mistake: "Improve reliability" with no engineering basis, or calling a part with a different specification a replacement in kind.
    Risk evaluation, pre- and post-change
    Why: Carries the impact on safety and health, (l)(2)(ii).
    Common mistake: Scoring only the end state and not the transition, when the plant runs half-changed.
    Stakeholder review and approval
    Why: Carries the authorization requirements, (l)(2)(v); five functions must each say yes or no.
    Common mistake: Approvals given by email outside the form, or one function signing for another who was away.
    Training and communication
    Why: Meets (l)(3): affected operating, maintenance and contract employees before start-up.
    Common mistake: Listing "operators" and forgetting the contractor crew who will work on the changed line.
    Verification at 30, 90, 180 days
    Why: The template's own follow-up convention for checking the change works as intended.
    Common mistake: Treating the 30-day check as the pre-startup safety review, which (i) requires before start-up.
    Closure and lessons learned
    Why: Closes the loop and records what the next similar change should do differently.
    Common mistake: Closing while a temporary change is still installed.

    Worked example

    IllustrativeTemporary bypass of a level transmitter (invented plant)

    BlockEntry
    Change descriptionMOC-2026-041 · Temporary · raised 3 June by the area engineer · Bypass around level transmitter LT-204 on the solvent day tank for up to 14 days while it is replaced. Technical basis: vendor lead time 10 days; manual gauging every 2 hours stands in for the high-level trip.
    Risk evaluationPre-change 2 × 5 = 10 (trip in service). Post-change with no extra controls 4 × 5 = 20. With 2-hourly gauging and filling limited to one pump 3 × 5 = 15, accepted for 14 days only.
    ApprovalOperations, engineering and maintenance approve 3 June · EHS approves with an end date of 17 June · Operations manager approves 4 June
    Training and communicationAll four shift crews briefed on manual gauging before start-up; the contract tank-cleaning crew informed by the permit issuer
    Implementation planRevise operating procedure OP-12 for manual gauging (area engineer, 4 June) · Mark the bypass on the control-room P&ID copy (engineering, 4 June) · Remove the bypass and prove the trip (maintenance, by 17 June)
    Verification and closureDay 14: bypass removed, trip tested. 30-, 90- and 180-day checks marked N/A: temporary change reversed. Lesson: hold a spare transmitter. Closed 18 June.

    Scored on the bands of the risk assessment matrix template: 20 is Extreme (stop work, executive sign-off), which is why the change needed its extra controls before approval.

    When a spreadsheet stops being enough

    Spreadsheet MOC registers fail in a predictable place: temporary changes that outlive their end date because nothing reminds anyone, and approvals collected by email that cannot be tied to the version of the change that was approved.

    A software record holds the approval sequence, can refuse closure until each consideration, the pre-startup review where one applies and the document updates are signed off, and can list overdue temporary changes. In a demo, ask to see a change rejected by one function and resubmitted, and what the history then shows.

    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. Documented and conditional capabilities qualify; check the linked scope before treating a module as included.

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

    All 10 matching profiles are shown. Documentation review, not hands-on testing or a claim of compliance.

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