Understand what MoC (management of change) is, what Brazil's NR 20 and NR 13 require when something changes in the operation, and how to build a 7-step MoC process.
By: Vitória Willemann
Content based on the official texts of NR 20 and NR 13, consulted on 06/11/2026.
MoC (Management of Change) is the process of assessing the risks of any change to equipment, processes, procedures or teams before it is made. In Brazil, NR 20 requires operating procedures to be revised based on the recommendations of the management of change system, and NR 13 requires a prior design for changes to boilers and pressure vessels.
| Standard | Item | What it requires when something changes |
|---|---|---|
| NR 20 | 20.9.2, point a | Revise operating procedures based on the recommendations of the management of change system |
| NR 20 | 20.5.4 | Modifications or expansions that affect safety must be preceded by a design with a risk analysis |
| NR 20 | 20.7.5, point b | Revise the risk analysis when there are significant process modifications |
| NR 20 | 20.12.9.1, point b | Refresher course within 30 days when a significant modification occurs |
| NR 20 | Annex I | The Advanced II course includes the basics of management of change |
| NR 13 | 13.3.7.3 and 13.3.7.4 | Alteration or repair design prepared or approved by a legally qualified professional and shared with the employees involved |
| NR 13 | 13.4.4.10, point b | Extraordinary boiler inspection after a major alteration or repair |
MoC stands for Management of Change. It is a formal process: every change that may affect safety is analysed, approved and communicated before it is carried out.
The concept comes from process safety. In the United States, for example, OSHA's process safety standard has an item dedicated to management of change (29 CFR 1910.119, item l). In Brazil, the topic appears mainly in NR 20, for facilities that handle flammables and combustibles.
The idea is simple: many accidents happen right after a change that seemed small, such as swapping a part for an "equivalent" one, altering a procedure or reassigning a team.
Any change that could alter the operation's risks. The most common types are:
Replacing a part with an identical one ("replacement in kind") does not usually require MoC. Changes can be permanent, temporary or emergency changes, and all of them must be assessed.
NR 20 is the Brazilian standard that directly mentions the management of change system. Under item 20.9.2, operating procedures must be revised every 3 years (classes I and II) or 5 years (class III), or earlier in certain situations. The first of these is a recommendation from the management of change system.
The standard also ties changes to other obligations:
For boilers and pressure vessels, NR 13 requires an alteration or repair design whenever the design conditions change or when a repair could compromise safety (13.3.7.3). This design must be prepared or approved by a legally qualified professional and shared with the employees who work with the equipment (13.3.7.4). It also becomes part of the equipment file.
An MoC process usually follows 7 steps:
Points to watch: temporary changes that become permanent without a new analysis, and training that does not keep up with the change, are common failures in this process.
Given how important the topic is for safe operations, GAP will soon have a module dedicated to management of change. In the meantime, Checklists and Inspections Management helps keep inspections of the operation's equipment up to date, with records of non-conformities and action plans with owners and deadlines.
For the training that a change requires, Employee Management records attendance, issues certificates and tracks the validity of each training course.
Want to make sure no change goes live without an up-to-date checklist and training? Schedule a demo.
MoC stands for Management of Change. It is the process of assessing, approving, communicating and recording changes to equipment, processes, procedures or teams before they happen, so that no new risk enters the operation uncontrolled.
In Brazil, NR 20 directly mentions the management of change system and requires procedures to be revised based on its recommendations (item 20.9.2). NR 13 requires an alteration or repair design for boilers and pressure vessels. In other sectors, MoC is good risk management practice.
A replacement in kind is a swap for an identical item or one that meets exactly the same specification, and it does not usually go through MoC. A change is anything that alters a specification, process, procedure or organisation and can therefore create new risks.
Yes. A temporary change also alters the risks while it is in place. It must be analysed and approved and have a set date to return to the original state or to be reassessed as permanent.
At NR 20 facilities, the refresher course must take place within 30 days of a significant modification (item 20.12.9.1, point b).
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Understand what NR 26 establishes, the official rules for safety signage, the use of the GHS in labelling and the preparation of the Safety Data Sheet.
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