MOC Safety Review Checklist

What management of change is

Management of change is the process of systematically evaluating a proposed modification before it is implemented, so that the change does not introduce unacceptable risks to personnel, property or the environment and does not put the facility out of step with applicable regulations. It applies to operational changes in a facility, and it is carried out before the change takes effect rather than after.

Why it matters

A single modification can have effects well beyond the equipment or area being changed. A change to a ventilation system may raise questions about compliance with applicable codes, standards or regulatory requirements. A change in how hazardous chemicals are used may alter existing permitted discharges to air or water, increase the onsite inventory of hazardous chemicals, or require hazardous chemicals to be stored or processed at elevated temperatures or pressures beyond current design parameters. A change can also affect supporting systems that were sized for the original operation — electrical power supply and utility services, instrumentation, indications and alarm systems, hazardous chemical detection or monitoring, fire suppression, site security and access control, and the location of emergency eyewash stations and safety showers. Reviewing the change in a structured way surfaces these questions while they can still be addressed.

What a good review covers

A thorough review starts with a clear description of the change: who is initiating it, what exactly is proposed, where it applies, how many personnel may be affected, and when implementation is planned. It then examines the change against the systems and safeguards already in place, asking whether each remains adequate: - **Compliance and permits** — whether the modification to any ventilation system would result in non-compliance with applicable codes, standards or regulatory requirements, and whether existing permitted discharges to air or water are altered and current environmental permits need modification. - **Hazardous chemicals** — whether the change increases the onsite inventory of hazardous chemicals, requires storage or processing at elevated temperatures or pressures beyond current design parameters, or introduces a need for additional detection or monitoring systems. - **Control and monitoring** — whether existing instrumentation, indications and alarm systems are insufficient to safely monitor and control the modified operations. - **Personnel protection** — whether the change introduces new hazards or risks that require additional personal protective equipment or other enhanced protection measures, and whether existing emergency eyewash stations and safety showers are insufficient or improperly located for the modified operations. - **External and site conditions** — whether the change introduces new vulnerabilities to external events not previously present, such as vehicle traffic impact, fire exposure, water accumulation or extreme weather conditions, and whether current site security procedures and access control measures remain sufficient. - **Utilities and structures** — whether the existing electrical power supply and utility services are inadequate for the modified operations, and whether current warehouse racking or structural storage capacity can safely accommodate the change. - **Fire response** — whether the existing fire suppression system is inadequate to respond to hazards associated with the modified chemical inventory or storage configuration. The review closes with an overall risk assessment rating, from 1 (low risk) to 5 (high risk), and confirmation that the change has been formally reviewed and approved by the appropriate facility management and safety personnel.

How to carry it out

Complete the change information first so the safety questions are answered against a clear description of what is actually changing. Then work through the safety review questions one at a time, answering Yes, No or N/A, and record what additional safeguards or engineering controls are required wherever an issue is identified. Where a question points to a gap — an inadequate fire suppression system, insufficient storage capacity, insufficient or poorly located eyewash and shower facilities — resolve it before the change is implemented, not afterwards. Finally, assign the overall risk assessment rating, confirm formal review and approval, note any remaining health, safety or environmental considerations, and sign off.

Frequently Asked Questions

The review works through three parts. Change Information captures the basics of the proposal: who is initiating it, a detailed description of the change, the affected area or location, the number of personnel potentially affected, and the proposed date and time for implementation. The Safety Review then works through a series of questions covering ventilation and compliance with applicable codes, standards or regulatory requirements, permitted discharges to air or water, onsite inventory of hazardous chemicals, storage or processing at elevated temperatures or pressures, hazardous chemical detection or monitoring, instrumentation, indications and alarm systems, personal protective equipment, vulnerabilities to external events, electrical power and utility services, site security and access control, emergency eyewash stations and safety showers, fire suppression, warehouse racking and structural storage capacity, and any other health, safety or environmental considerations. The review closes with an overall risk assessment rating from 1 (low risk) to 5 (high risk) and a signature.

Management of change matters because a modification made in one part of a facility can create consequences elsewhere. A change to a ventilation system may affect compliance with applicable codes, standards or regulatory requirements; a change in chemical use may alter permitted discharges to air or water, raise the onsite inventory of hazardous chemicals, or affect fire suppression. Changes can also affect less obvious things such as electrical power and utility capacity, site security and access control, the location of emergency eyewash stations and safety showers, and the ability of warehouse racking or structural storage to safely accommodate what is proposed. Reviewing these questions before implementation lets you identify whether additional safeguards, engineering controls, detection or monitoring, personal protective equipment, or permit modifications are needed.

Complete the Change Information section first so that the safety questions are answered against a clear description of what is actually changing. Work through the Safety Review questions one by one, answering Yes, No or N/A as appropriate. Where a question identifies an issue — for example, that the change alters permitted discharges and may require modifications to current environmental permits, or that it introduces new vulnerabilities to external events such as vehicle traffic impact, fire exposure, water accumulation or extreme weather — record what additional safeguards, engineering controls or other measures are required. Assign an overall risk assessment rating from 1 (low risk) to 5 (high risk), confirm the change has been formally reviewed and approved by the appropriate facility management and safety personnel, note any remaining health, safety or environmental considerations, and sign off.

Written by

Arne Reis

Founder

Process optimizer with 25 years of expertise, focused on operational excellence in quality, maintenance, EHS, and commissioning. Emphasizes innovative solutions and top-quality standards.

View LinkedIn profile