In brief
The Risk Assessment Regulation requires the risk assessment to be renewed in full or in part without waiting for the period to expire when technology, substances or equipment, the production method or the building changes. The way to secure this on site is a management of change (MOC) form completed before the change is made, and a traceable revision record in the risk document. In this article we set out the form's fields, the approval steps and how to keep the revision record, with examples.
What does management of change do in workplace safety?
A new press is arriving at the factory, the solvent supplier on the paint line is changing, the forklift route is being moved because the warehouse is growing. Each is an ordinary decision from a production point of view; from an occupational health and safety point of view, however, it can invalidate the assumptions in the risk assessment. Management of change is the written process that catches these decisions before they are implemented, assesses their impact and updates the risk document. In the process safety literature it is known by the abbreviation MOC (management of change).
Management of change solves two problems in workplace safety. First, it prevents changes being made without the OHS team being told. Second, it stops the risk assessment sitting out of date until the next renewal date. For the basic steps of risk assessment, see our article on how to carry out a risk assessment; here we deal only with the moment of change.
Legal basis: when is the risk assessment revised?
Art. 12 of the Regulation on Occupational Health and Safety Risk Assessment requires the risk assessment to be renewed at least every 2 years in very hazardous workplaces, every 4 years in hazardous ones and every 6 years in less hazardous ones. The same article provides for renewal in full or in part without waiting for the period to expire in the following situations:
- Relocation of the workplace or changes to buildings,
- Changes in the technology applied at the workplace and in the substances and equipment used,
- Changes in the production method,
- A workplace accident, occupational disease or near miss,
- A change in legislation on limit values relating to the working environment,
- Where the results of workplace measurements and health surveillance make it necessary,
- A new hazard originating outside the workplace.
The first three items on the list are directly the subject of management of change. Law No. 6331 also links to the same point in two places: Art. 17 requires workers to be trained when work equipment changes or new technology is introduced; Art. 18 requires workers to be consulted on the introduction of new technologies and the work equipment to be chosen. A good MOC form therefore also includes the training and worker consultation steps.
Which changes go on the form?
Tying every light bulb change to a form makes the process unworkable. Define the scope in writing from the outset. The table below is a reasonable starting point for production businesses.
| Type of change | Example | Main checks it triggers |
|---|---|---|
| New or second-hand machine | Press, CNC, robot cell, conveyor | CE and declaration of conformity, guards, initial inspection, LOTO points, training |
| Machine modification | Guard removed and redesigned, speed increase, automation added | Effect of the modification on safety functions, revalidation |
| New chemical or change of supplier | Different solvent, new cleaning chemical | Safety data sheet, storage compatibility, PPE, need for workplace measurement |
| Layout change | Moving a line, adding racking, moving a walkway | Forklift and pedestrian segregation, escape routes, emergency plan and evacuation plan |
| Process parameter | Change in temperature, pressure, speed or recipe | Pressure equipment limits, heat and steam risks, safety valves |
| Building and services | New partition, closing a door, adding an electrical panel | Escape distance, fire detection, electrical installation inspection |
| Temporary change | Bridging a sensor because of a fault, temporary hose or cable | Time limit, compensating measure, reversal date |
For chemical changes, the first document to check is the safety data sheet; for how to read it, see our article on how to read a safety data sheet.
The MOC procedure: 7 steps before the change
An MOC procedure consists of sequential steps running from the person proposing the change to approval for commissioning.
- Request: The unit proposing the change completes the first section of the form: what is changing, why, where and when.
- Screening: The person responsible for OHS or the OHS specialist decides whether the change is in scope. "Like for like" (a one-to-one replacement with the same make, model and settings) is often out of scope; but mark this in writing.
- Risk assessment: The risk assessment team meets for the departments affected by the change. Under the regulation, the team includes the employer or their representative, the specialist, the workplace physician, the employee representative, support staff and workers who know the relevant department. The maintenance or project lead who will make the change should also be at the table.
- Agreeing measures: Measures are chosen according to the hierarchy of controls; first design and engineering measures, then procedures and training, and PPE last. For the method, see our article on the hierarchy of controls.
- Worker consultation and training: The views of workers affected by the change are sought, a new instruction is prepared and training is delivered. The training record is attached to the form.
- Pre-commissioning check: It is verified on site that the measures have been implemented. For equipment, the initial inspection report is checked; for chemicals, storage and labelling; for layout, floor markings and signs.
- Approval and close-out: Commissioning approval is given, the revision record of the risk assessment is entered and, if necessary, the emergency plan and evacuation plan are updated.
Management of change form: sample fields
The form can be a single page; what matters is that each field has an owner and a date.
| Section | Information to complete |
|---|---|
| Identification | Form no., request date, requesting unit and person |
| Description of the change | Current situation, proposed situation, justification, location, planned date |
| Type | Machine / chemical / layout / process / building / temporary (with end date) |
| Affected parties | Departments, shifts, subcontractors, number of workers |
| Screening | In scope? Yes/no with justification, signature |
| Hazards and risks | New or changed hazards, risk score (before/after), method used |
| Measures | Owner and deadline for each measure |
| Documents | Declaration of conformity, user manual, safety data sheet, initial inspection report |
| Training and information | Who, which topic, date, attendance list |
| Documents to be updated | Risk assessment, instructions, emergency plan, chemical inventory, PPE matrix |
| Commissioning approval | Signatures of the specialist, department head and employer representative |
| Close-out | Date the revision record was entered |
Risk assessment revision and the revision record
Risk assessment revision does not mean rewriting the whole document from scratch. The regulation allows partial renewal; the department, machine or activity rows affected by the change are updated. However, which row changed, when and why must be traceable. To do this, add a revision table at the start of the document:
| Rev. | Date | Change (MOC no.) | Affected department / rows | Prepared by |
|---|---|---|---|---|
| 03 | 12.01.2027 | MOC-2027-004: Robot added to welding cell | Welding department, rows 41–48 | Specialist, physician, employee representative |
| 04 | 19.01.2027 | MOC-2027-006: Degreasing chemical changed | Pre-treatment, rows 12–15; chemical inventory | Specialist, physician, department head |
The table is a practical example. The regulation requires the method used to be stated in the document, the pages to be initialled and the last page signed; revised pages are initialled in the same way. After measures are implemented, the risk level is determined again; if the new level is above the acceptable level, the steps are repeated. Methods such as Fine-Kinney or, for a new line, FMEA can be used; the legislation does not make any specific method mandatory.
The revision record also makes the team's work easier at the next general renewal: what has changed over the last few years is visible in a single table. You can use the OHS calendar tool to track how changes affect renewal dates.
New machine risk assessment: before commissioning
New machine risk assessment starts not after the machine enters the factory but when the purchasing specification is written. In purchasing, ask for: CE marking and the EU declaration of conformity, a user manual in Turkish, a description of guards and safety circuits, energy isolation points and maintenance instructions. The new Machinery Safety Regulation (2023/1230/EU), which governs the placing of machinery on the market, was published on 16 October 2026 and most of its provisions enter into force on 20 January 2027; until then, the 2009 regulation based on 2006/42/EC applies. For details, see our article on the Machinery Safety Regulation and CE marking.
CE marking does not mean the machine will be safe on your line. The machine's infeed and outfeed sides, the conveyor next to it, the operator's access routes and the tasks carried out during maintenance are the subject of your risk assessment. For second-hand or old machines without CE marking, our article on compliance of old machines without CE marking offers guidance. For the check required before commissioning, see our article on initial inspection of work equipment.
Line changes are frequent in automotive supplier and machinery businesses in Bursa and neighbouring provinces; a new cell arriving with a customer project can be commissioned within a few weeks. At this pace, making the MOC form a milestone in the project schedule is the most practical way to secure the change without slowing it down. In our risk assessment service, we set up the form and revision record together according to your business's structure, and follow up open forms during our OHS specialist visits.
Frequently Asked Questions
Is the risk assessment redone from scratch with every machine change?
No. Art. 12 of the Risk Assessment Regulation requires the risk assessment to be renewed in full or in part when technology, substances or equipment change. It is enough to update the departments and rows affected by the change and enter this in the revision record.
Is an MOC procedure a legal requirement?
The legislation does not require a document called an "MOC form". What is mandatory is that the risk assessment is renewed when a change occurs, training is delivered and workers are consulted. The MOC form is a practical tool for not missing these obligations.
Does replacing a machine with the same model go on the form?
A one-to-one replacement with the same make, model and settings can often be left out of scope. However, record this decision in writing in the screening section; if the layout, feed direction or guard type changes, the change is in scope.
Who signs the revised risk assessment?
The risk assessment team that prepared the revision signs it. The team includes the employer or their representative, the OHS specialist, the workplace physician, the employee representative, support staff and workers who know the relevant department; the pages are initialled and the last page is signed.
A risk assessment that identifies and scores hazards on site, links each measure to an owner and a date, and has a clear renewal schedule.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.