The correct answer is A (True) because CCPS Risk-Based Process Safety clearly states that a Management of Change (MOC) system must address all types of changes that could impact process safety and can be reasonably anticipated .
These changes include modifications to process technology, equipment, procedures, chemicals, operating conditions, and organizational structure . CCPS emphasizes that even seemingly minor changes can introduce new hazards or alter existing risk profiles, making it essential that they are systematically identified and evaluated.
The phrase “reasonably foreseen” is important. It acknowledges that while not every possible scenario can be predicted, organizations are expected to anticipate typical and credible changes based on experience, design knowledge, and operational practices. This includes both permanent and temporary changes, as well as emergency changes (which may follow an expedited but still controlled process).
A robust MOC system ensures that hazards are assessed, safeguards are reviewed, documentation is updated, and personnel are trained before implementation. Failure to capture foreseeable changes is a common root cause of major process safety incidents.
Therefore, CCPS considers it essential that MOC systems are comprehensive in scope , covering all foreseeable changes to maintain process safety and operational integrity.
