Last reviewed: October 2026
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This free management of change (MOC) checklist is for process safety leads, plant and process engineers, operations managers and EHS teams at sites that handle hazardous chemicals. One run is one proposed change to a process, plant, equipment, chemicals, an operating procedure or the organisation, from the request to close-out. It first decides whether the proposal is a change at all or a replacement in kind, then classifies it as permanent or temporary and normal or emergency, runs a hazard review and checks the impact on process safety information, P&IDs, relief and safety systems, procedures and training. The authoriser approves the change before work starts, the records are updated and affected employees and contractors are trained before start-up, and a pre-startup safety review comes before the authorisation to start up. A US, UK or other answer adds the matching OSHA or COMAH notes, and a temporary change adds the tasks that track it to its expiry.
Management of change asks one question before anything is altered on a hazardous process: what could this change do to the safeguards we rely on? In the US, OSHA’s Process Safety Management standard requires written procedures to manage changes to process chemicals, technology, equipment and procedures, and changes to facilities that affect a covered process, other than replacements in kind. In Great Britain, COMAH requires the safety management system of a major hazard site to address the management of change.
This checklist runs one such change from the request to close-out. It sits beside other kinds of change control, and each answers a different question. Changes to IT systems go through the IT Change Management Process Checklist.
Asks: what does this change to chemicals, plant, equipment, procedures or the organisation do to process safety, and is everyone ready before start-up?
When: before any change other than a replacement in kind at a site that handles hazardous materials.
Output: an authorised change, updated process safety information and procedures, trained people and a pre-startup safety review.
Asks: how does a change to a product’s design, bill of materials or routing affect quality, cost and stock?
When: for engineering changes, in the Manufacturing Change Order Process Checklist.
Output: an approved change order, updated documents and dispositioned inventory.
Asks: is this job controlled while people work on the plant?
When: for each job that installs the change, in the Permit to Work Checklist and the Lockout/Tagout (LOTO) Procedure Checklist.
Output: a permit issued and closed, and isolations made, proved and removed.
Eight phases follow one change from the request to close-out. A replacement in kind is recorded and closed in Phase 1, and the remaining tasks are marked not applicable. A temporary change adds the expiry tasks in Phase 8, an emergency or organisational change adds its own task in Phase 2, open recommendations add a task to resolve them, a UK answer adds the COMAH task in Phase 5, and the authoriser approves the start-up after the pre-startup safety review.
The change owner raises the request and the MOC coordinator decides whether it is a change at all. A replacement in kind closes here; anything else runs the full procedure. Every due date counts back from the planned start-up date.
Classification sets the time period, the depth of the review and who authorises the change. A temporary change adds an expiry date and the tasks that track it; an emergency change adds a record of who authorised it and what was reviewed first.
Match the method to the size and hazard of the change. Look beyond the item being changed: effects can appear in parts of the plant far from it.
Check every record, system and group of people the change touches before it is authorised, so nothing is found for the first time at start-up.
The change is authorised by the people your procedure names before any work starts. On a UK COMAH site the notification and safety report task appears here, because both come before the modification is made.
Do the work under your permit-to-work and lockout procedures. The process safety information, procedures and training are brought up to date before start-up, not after.
The pre-startup safety review confirms the plant and the people are ready before hazardous chemicals are introduced. Nothing after the start-up authorisation can be completed until the authoriser records a decision.
A temporary change is tracked to its expiry so it never becomes permanent by default. The MOC closes only when the final records are issued and every action is complete.
The US writes the steps of management of change into the PSM standard. In Great Britain, COMAH requires a management of change procedure and says when the competent authority must be told, and HSE’s technical guidance describes good practice. Use the table to check your own procedure; it is not legal advice.
| Topic | US: OSHA 29 CFR 1910.119 | Great Britain: COMAH 2015 and HSE guidance |
|---|---|---|
| Who it applies to | A process with a listed highly hazardous chemical at or above its Appendix A threshold quantity, or 10,000 lb or more of a Category 1 flammable gas or a flammable liquid with a flashpoint below 100 °F, with exceptions. Not retail facilities, oil or gas well drilling or servicing, or normally unoccupied remote facilities ((a)) | Lower tier and upper tier establishments, where a dangerous substance is present at or above the quantities in Schedule 1 (regulations 2 and 3) |
| What must be managed | Changes to process chemicals, technology, equipment and procedures, and changes to facilities that affect a covered process, under written procedures ((l)(1)) | The safety management system must address the management of change: procedures for planning modifications to, or the design of, new installations, processes or storage facilities (Schedule 2, paragraph 2(d)). HSE’s guidance: all modifications, whether to procedures, plant and equipment, people or substances, under formal management procedures |
| Replacement in kind | A replacement which satisfies the design specification ((b)); outside the MOC procedures ((l)(1)) | Not defined in the Regulations; set the rule in your own procedure |
| Before the change | The technical basis, the impact on safety and health, modifications to operating procedures, the necessary time period and the authorisation requirements ((l)(2)) | HSE’s guidance: no modification without a traceable safety, engineering and technical review of process conditions, operating and engineering methods, safety, environmental conditions and hardware and design, then a risk assessment that includes fire, explosion and loss of containment |
| Hazard review method | Not set for changes. The non-mandatory Appendix C suggests a checklist reviewed by an authorised person for a minor, well-understood change, and a hazard evaluation with operations, maintenance and safety approvals for a complex one | HSE’s guidance: written procedures decide what level of HAZOP, if any, applies, based on the degree of hazard, the extent of the change, the worst case accident and previous HAZOPs |
| Authorisation | Authorisation requirements addressed before the change ((l)(2)(v)) | HSE’s guidance: formally authorised, after technical investigation, by competent personnel of senior status |
| People | Employees operating the process, and maintenance and contract employees whose tasks are affected, informed of and trained in the change before start-up ((l)(3)) | The safety management system identifies training needs and provides the training (Schedule 2, paragraph 2(a)(ii)). HSE’s organisational change guidance: training and supervision for people in new or changed roles |
| Records | Process safety information and operating procedures updated when the change affects them ((l)(4), (l)(5)) | HSE’s guidance: accurate recording and monitoring of changes to plant and process, and only authorised personnel amend operating procedures or issue temporary operating instructions |
| Before start-up | A pre-startup safety review for a modified facility when the change needs a change in the process safety information, before highly hazardous chemicals are introduced ((i)) | HSE’s guidance: a pre-commissioning check, including statutory requirements, is a HAZOP study stage for plant modifications too; modifications are proved to have achieved the design intent |
| Temporary changes | Not in the standard’s text. Appendix C: subject to MOC, with a time limit set and monitored, and a return to the original or designed condition at the end | HSE’s guidance: only authorised personnel issue temporary operating instructions during a change |
| Telling the regulator | No notification to OSHA in paragraph (l) | Notify the competent authority in advance of any modification that could have significant consequences for major accident hazards (regulation 6(6)(c)). Upper tier: review the safety report before such a modification and send the revised parts in advance (regulation 10(2)(d) and (5)) |
Organisational change. HSE says changes such as reduced staffing, outsourcing, merged departments or new roles are usually not analysed and controlled as thoroughly as plant or process changes. Plan them in the same systematic way, and assess both the end state and the transition. OSHA’s list in paragraph (l)(1) does not name organisational changes.
Inventory and tier. A modification that changes the inventory of dangerous substances can move a COMAH establishment into a different tier, and the major accident prevention policy must be reviewed after a significant change in the processes that could have significant consequences (regulation 7(6)).
The change owner, MOC coordinator, authoriser and operations lead are chosen on the first task, and each step is assigned to the person who owns it. The start-up authorisation is assigned to the authoriser alone, and nothing after that approval step can be completed until a decision is recorded.
A replacement in kind adds one task to record it and close the request, with the remaining tasks marked not applicable. A temporary change adds an expiry date and the tasks that track it, open recommendations add a task to resolve them, and a UK answer adds the COMAH task. Rules show and hide each one from the answers given.
Due dates count back from the planned start-up date, and overdue alerts go to the task’s assignees. The Reports Grid lists every change in progress and the task each one has reached, with the hazard review, drawings, test records and training record on the tasks that produced them.
CheckFlow does not run hazard studies or size relief valves. That stays with your engineers, your hazard review team and your design codes. It makes sure every change is reviewed, authorised, recorded and closed in order, by the right people, with the evidence attached. CheckFlow’s manufacturing checklist software shows how the same approach runs other plant routines.
Install the change under the Permit to Work Checklist and the Lockout/Tagout (LOTO) Procedure Checklist. A change to what the plant makes goes through the Manufacturing Change Order Process Checklist, and a change to IT systems through the IT Change Management Process Checklist. For a structured failure analysis use the FMEA Checklist, and for the hazards of a single job the Job Hazard Analysis (JHA) Checklist.
Permit to Work Checklist
Lockout/Tagout (LOTO) Procedure Checklist
Manufacturing Change Order Process Checklist
FMEA Checklist
Job Hazard Analysis (JHA) Checklist
Describe the process in a sentence and the AI checklist generator drafts the phases and tasks for you.
A written procedure for reviewing and authorising a change to a process that handles hazardous materials before it is made. In the US, OSHA’s Process Safety Management standard, 29 CFR 1910.119(l), requires one for changes to process chemicals, technology, equipment and procedures, and changes to facilities that affect a covered process, other than replacements in kind. In Great Britain, COMAH 2015 requires a major hazard site’s safety management system to address the management of change. A typical MOC records the technical basis, reviews the hazards, updates the records and trains the people affected before start-up.
OSHA defines it as a replacement which satisfies the design specification, and replacements in kind are outside the management of change procedures in 1910.119(l). A part that meets the same specification as the one it replaces is a replacement in kind; a different material of construction, size, rating or chemical is a change. OSHA’s non-mandatory Appendix C lists changes in materials of construction, equipment specifications, alarms and interlocks and computer program revisions among the equipment changes MOC covers. When in doubt, treat it as a change.
Paragraph (l)(2) lists five considerations: the technical basis for the change, its impact on safety and health, modifications to operating procedures, the necessary time period for the change, and the authorisation requirements. Paragraph (l)(3) requires employees operating the process, and maintenance and contract employees whose tasks are affected, to be informed of and trained in the change before start-up. Paragraphs (l)(4) and (l)(5) require the process safety information and the operating procedures to be updated when the change affects them.
Under 1910.119(i), for new facilities, and for modified facilities when the modification is significant enough to require a change in the process safety information. Before highly hazardous chemicals are introduced, the review confirms that construction and equipment match the design specifications, that safety, operating, maintenance and emergency procedures are in place and adequate, that the modified facility meets the management of change requirements, and that training of each employee involved in operating the process is complete. This checklist runs the review before every start-up after a change.
Yes. Schedule 2 of the COMAH Regulations 2015 says the safety management system must address the management of change: procedures for planning modifications to, or the design of, new installations, processes or storage facilities. The operator must notify the competent authority in advance of any modification that could have significant consequences for major accident hazards, and an upper tier establishment must review its safety report before such a modification and send the revised parts in advance. HSE’s technical guidance on plant modification describes good practice for the review.
As changes, with an end date. OSHA’s non-mandatory Appendix C to 1910.119 says temporary changes are subject to management of change, that a time limit should be set and monitored because uncontrolled temporary changes may tend to become permanent, and that equipment and procedures should go back to their original or designed condition at the end. This checklist records the expiry date, reviews the change two weeks before it, and restores the design or takes the change through a new MOC as a permanent one.
HSE’s guidance says they should be planned in a thorough, systematic way, similar to plant changes. It notes that reduced staffing, outsourcing, merged departments and new roles are usually not analysed as thoroughly as plant or process changes, and recommends assessing both the end state and the transition, consulting staff and contractors, transferring key tasks and training people in new roles. OSHA’s list in 1910.119(l)(1) does not name organisational changes. Tick Organisation, staffing or roles on the first task to add the transition assessment.
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