Why Management of Change matters

Most dangerous goods incidents don't start with something dramatic. They start with an ordinary decision, like a cheaper supplier, a bigger order or a new forklift, that nobody stopped to think through. Management of Change is how you do that thinking, every time, and keep proof that you did. That holds whether you run a single chemical shed or a large processing site.

What is Management of Change?

Management of Change (MOC) is a simple, repeatable way to check a change before you make it. You ask what could go wrong, decide what controls are needed, get the right person to approve it, make sure it was done properly, and record the lot.

Typical changes that should go through MOC include:

• bringing in a new chemical, or a significant increase in the quantity of a chemical or class;
• changing pack size, for example from 205 L drums to a 1,000 L IBC;
• replacing or modifying equipment, such as a new forklift or altered pallet racking;
• staff, contractor or organisational changes;
• a new service provider, for example for maintenance or fire-extinguisher servicing.

It applies to temporary changes too, such as storing extra stock "just for the busy season".

A global process safety practice

MOC is a core element of process safety worldwide:

• In the United States, OSHA's process safety management rule requires written procedures to manage changes to chemicals, technology, equipment, procedures and facilities. Before a change, the technical basis, safety impact, procedure updates and authorisation must be addressed, and affected workers must be trained before start-up. [2]
• In the United Kingdom, HSE guidance for major hazard (COMAH) sites expects all modifications, whether to procedures, plant, people or substances, to go through formal, traceable review and authorisation. [3]
• The Center for Chemical Process Safety (CCPS) lists MOC as a core element of its Risk Based Process Safety framework. It also notes that lower-risk sites can run MOC less formally than high-hazard plants. MOC scales to the size of the operation. [4]
• Workplace health and safety management systems used internationally expect planned temporary and permanent changes to be managed.

The lesson these frameworks share goes back to Flixborough, UK, 1974. A temporary bypass pipe was fitted to keep a chemical plant running after a reactor was removed. The modification wasn't properly designed or assessed. When it failed, the vapour cloud explosion killed 28 people. [6]

Why it's expected of you in Australia

Work health and safety law

• Before a change. Under the WHS Regulations, control measures must be reviewed, and revised as needed, before a change at the workplace that is likely to create a new or different risk (regulation 38). This applies under Safe Work Australia's model WHS Regulations and under WA's Work Health and Safety (General) Regulations 2022. [7][8]
• Hazardous chemicals. You must keep a hazardous chemicals register, and review control measures when the register or a safety data sheet changes (WA r 346 and r 352). [8][9]
• Major hazard facilities. For the largest sites, the model WHS Regulations define a "modification" (r 534). They require the safety assessment, emergency plan and safety management system to be reviewed when a modification is proposed, and the safety management system must describe procedures for planning modifications ("Management of change", Schedule 17). [7]

Western Australia: dangerous goods law

• The general duty. Under section 8 of the Dangerous Goods Safety Act 2004, anyone storing or handling dangerous goods must take all reasonably practicable measures to minimise risk to people, property and the environment. You can't show you've minimised the risk of a change you never assessed. [10]
• Thresholds and paperwork. The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 set placarding and manifest quantities. Above them, placards, a manifest and site plan, a written risk assessment and a dangerous goods site licence may be needed. A "small" change in quantity or pack size can push you over a threshold. [10][11]
• Review when things change. The risk assessment must be reviewed when there is a significant change to the site or its storage, after a reportable incident, and at least every five years. [12]
• Major hazard facilities in WA must review and update their safety report, including the risk assessment and safety management system, before a significant change to plant, processes, substances or layout (Dangerous Goods Safety (Major Hazard Facilities) Regulations 2007, r 30). [13]

In plain terms: if a change takes you past a placarding or manifest quantity, your placards, manifest, site plan, risk assessment and licence may all need to change too. MOC is how you catch that before an inspector does.

Australian Standards

WorkSafe WA lists Australian Standards that are referenced in dangerous goods safety legislation. [14] Australian Standards for dangerous goods storage and handling expect a site to manage change. In general, that means checking a change to equipment, processes, procedures or people before it is made, including a temporary change, and reviewing procedures, risks or site conditions when something on the site changes. New or modified equipment may also need to be commissioned.

In WA, some codes and standards are prescriptive and must be followed. Others are not mandatory but are the usual benchmark, and departures need to be justified. [14] Which standards apply depends on what you store, so check with your regulator or a DG consultant.

What goes wrong without it

Without a check:

• a new product is stored next to something incompatible, for example an oxidiser beside a flammable liquid;
• quantities creep past a placarding or manifest quantity, and the paperwork no longer matches reality;
• bigger containers outgrow the spill containment or racking they sit on;
• a new forklift, contractor or staff member works without the training or procedures the change needed;
• a "temporary" arrangement quietly becomes permanent.

What it can mean for your business

• Evidence: an MOC record is often the clearest evidence that you took reasonable steps.
• Licence and approvals: a change to what you store may affect your licence and its conditions.
• Insurance: insurers commonly ask how hazards are managed, so check your policy.
• People and property: above all, MOC protects your staff, neighbours, emergency responders and your premises.

Good news: MOC doesn't need to be complicated. It needs to be consistent, proportionate to the change and written down, whether you have one shed or fifty.

How Mocos helps

Mocos, by Perth-based CosmoHealth Solutions, is a management of change record for dangerous goods sites. It is simple for a single store and can grow into a staged workflow for a larger operation:

• a structured workflow from raising and screening a change, through risk assessment, approval, implementation and verification, to close-out;
• screening that prompts for common change triggers, separates permanent from temporary changes, controls like-for-like exemptions, and flags when quantities approach WA placarding or manifest thresholds;
• a built-in DG review prompt that flags changes likely to need a dangerous goods review, with a Request a DG review button. Reviews are quoted per review, and included reviews come with the Higher plan. Nothing is shared without your consent;
• a company profile holding your site details, DG inventory, procedures, site plan, licence and manifest information, so the right documents get updated;
• record keeping for at least 10 years, with a tamper-evident audit trail, regulator-ready PDF and CSV exports, and data stored in Australia.

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General information only. This page is not legal, engineering or professional advice. Requirements vary between states and territories and change over time, and other laws and standards may apply to your site. Check the current legislation and talk to your regulator (in WA, the Department of Energy, Mines, Industry Regulation and Safety, through WorkSafe and Dangerous Goods Safety) or a qualified consultant. Using Mocos does not by itself make a site compliant.

References

1. US OSHA, 29 CFR 1910.119(l) Management of change: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.119
2. UK Health and Safety Executive, Plant modification / Change procedures (COMAH technical measures): https://www.hse.gov.uk/comah/sragtech/techmeasplantmod.htm
3. CCPS (AIChE), Introduction to Management of Change (Risk Based Process Safety): https://ccps.aiche.org/introduction-management-change
4. UK HSE, Flixborough (Nypro UK) Explosion, 1 June 1974: https://www.hse.gov.uk/comah/sragtech/caseflixboroug74.htm
5. Safe Work Australia, Model WHS Regulations (1 Sept 2024), r 38, r 534, r 559, r 569, Sch 17: https://www.safeworkaustralia.gov.au/sites/default/files/2024-08/consolidated_model_whs_regulations_-1_september_2024.pdf
6. Work Health and Safety (General) Regulations 2022 (WA): https://www.legislation.wa.gov.au/legislation/statutes.nsf/law_s53267_currencies.html; r 38: https://www8.austlii.edu.au/au/legis/wa/consol_reg.20230606/whasgr2022382/s38.html; r 352: https://www6.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_reg.20230606/whasgr2022382/s352.html
7. WorkSafe WA, Hazardous chemicals register: https://www.worksafe.wa.gov.au/hazardous-chemicals-register
8. WorkSafe WA / DEMIRS, Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 – guide: https://www.worksafe.wa.gov.au/system/files/documents/2025-01/DGS_G_SH_Regs.pdf
9. DEMIRS, Guidance note – Licensing and exemptions for storage and handling: https://www.worksafe.wa.gov.au/system/files/documents/2025-01/DGS_GN_LicensingAndExemptionsStorageAndHandling.pdf
10. DEMIRS, Risk assessment for dangerous goods – guide: https://www.wa.gov.au/media/50194/download?inline=
11. WorkSafe WA, Requirements of different stages of life for a major hazard facility: https://www.worksafe.wa.gov.au/requirements-different-stages-life-major-hazard-facility
12. WorkSafe WA, Dangerous goods codes of practice and guidance: https://www.worksafe.wa.gov.au/dangerous-goods-codes-practice-and-guidance