Management of Change (MoC)
Not every change is equal: a formal MoC process distinguishes a modification that requires a structured risk assessment from one that can proceed without.
Operational Explanation
The Management of Change (MoC) is the process, increasingly recognised as an essential component of a compliant Safety Management System, that governs the approval, implementation and monitoring of changes at Company or ship level: new equipment, procedural changes, manning changes, changes to operating routes or the type of cargo handled.
A structured MoC process is typically organised in distinct phases: initiation of the change request (with rationale, responsible department and urgency level), assessment of the impact and risk associated with the proposed change, formal approval by the appropriate management level, any training required for the personnel involved, and finally a completion verification identifying any residual risks and the related mitigation actions.
The crucial difference from informal change management is that MoC forces an explicit distinction between minor changes, which can proceed with a simplified assessment, and significant changes, which require a structured risk analysis before implementation.
Regulatory Reference
There is no single article of the ISM Code explicitly dedicated to MoC by name, but the process is considered an essential component of substantive (not merely formal) compliance with the Code's general requirements on risk identification and continuous improvement of the Safety Management System.
Scope of Application
Every significant change at Company or ship level: new equipment or systems, procedural changes, changes to key manning, changes to operating routes, new types of cargo handled.
Procedure / How to Complete It
- Formalise every significant change request with a rationale, responsible department, detailed description and urgency level.
- Conduct an assessment of the impact and risk associated with the proposed change, identifying potential hazards and consequences.
- Obtain formal approval of the change from the appropriate management level, proportionate to the significance of the change.
- Deliver the necessary training to the personnel involved before the change is actually implemented.
- Verify completion of the change as planned, identifying any residual risks and the related mitigation actions.
Practical Example
Example of application: the introduction of a new cargo type not previously carried by the ship is subjected to a formal MoC process, with a specific risk assessment, approval by the Technical Director and dedicated crew training before the first loading of the new cargo type.
Real Cases
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Changes implemented informally without going through a structured assessment process | Risks associated with the change not identified before implementation | Always formalise an MoC process for significant changes, proportionate to their significance |
| No distinction between minor and significant changes in the approval process | Minor changes needlessly delayed, or significant changes approved without adequate assessment | Define clear criteria to distinguish minor changes from those requiring a full structured assessment |
| Change completion verification omitted, without identification of residual risks | Residual risks left unmanaged after the change is implemented | Always include a final verification stage with explicit identification of residual risks and mitigations |
PSC Observations
Operational Tips
- Formalise a proportionate MoC process: not every change requires the same level of assessment.
- Define clear, shared criteria to distinguish minor changes from significant ones.
- Never consider a change complete without a final verification that explicitly identifies any residual risks.
Checklist
- Change request formalised with rationale, department and urgency level
- Impact and risk assessment conducted before approval
- Approval obtained from the appropriate management level
- Training delivered to personnel involved before implementation
- Completion verification conducted with identification of residual risks