Responding is Monica Kinsey, marketing manager, Frontline Data Solutions, Troy, MI.
Management of change process failures typically don’t start with an incident. They start with a shortcut.
Maybe someone makes a small equipment change without doing a full review. Or maybe an important procedure no longer matches the way work actually gets done. Another common risk is a temporary fix that stays in place longer than intended. Although these issues may seem minor, they often signal that the MOC process is starting to fail. In high-risk industries such as chemical manufacturing, this is usually the beginning of expensive equipment failures, unplanned downtime or safety incidents.
That’s what makes early warning signs so important. Safety pros don’t need to wait for an audit finding or an injury to know the process needs attention. Often, process breakdowns show up in daily work long before incidents happen.
Inconsistency is a clear warning sign. When sites, shifts or departments manage similar changes differently, the MOC process no longer guides decision-making. A strong MOC process should create structure for evaluating risk, assigning responsibility and confirming readiness before startup.
Here are some common warning signs to look for:
- Similar changes go through different review or approval steps
- Teams can’t quickly tell which changes are open, overdue or ready for startup
- Procedures, drawings or training records don’t match current operations
- Employees rely on verbal approvals or informal workarounds
- Temporary changes stay in place long after their original time frame
Each of these points to the same problem: a company that treats MOC as a routine task instead of a managed safety process.
Poor visibility is another red flag. If leaders can’t easily answer who owns a change, what actions remain open, or whether affected documents and training have been updated, the MOC process has already started to weaken. Depending on one person’s memory or wasting time searching for records increases operational risk.
Documentation gaps are another sign of failure. If teams can’t clearly explain why a change is happening, how it affects safety and health, what needs to be updated, or who’s in charge of sign-off, the process is reactive. MOC programs should answer those questions before implementation, not after something goes wrong.
Safety leaders should also pay attention to how employees talk about MOC. When workers dread it, they’re more likely to cut corners. Comments such as “We’ll fix the paperwork later” or “This change is too small to count” often signal a deeper cultural problem. In this case, the MOC process may no longer shape daily decisions.
Watch what happens after approval. Many processes fail during follow-through, not review. Teams may skip training or neglect to update procedures. Or maybe temporary changes become permanent and lessons learned never make it back into the process.
The good news is that these warning signs are visible. When safety leaders spot repeated workarounds, weak documentation, poor visibility and inconsistent execution, they can step in early. MOC shouldn’t slow down work. It should ensure changes happen with the same discipline applied to every other critical safety process.
Editor’s note: This article represents the independent views of the author and should not be considered a National Safety Council endorsement.
