(11c) Management of Change (MOC) Auditing System

Our company has discovered that regular auditing of the MOC process is essential to enforcing its proper use. We have developed an audit that can be performed by plant personnel to identify the effectiveness of our MOC process in 2 critical categories: (1) Identifying changes and initiating MOC for them (2) After MOC is initiated, following the process correctly and completely. In addition, we have a set of measures associated with these audits that we can track to give us an overall picture of how effectively our MOC process is operating and identify any systemic issues. The audit form and process will be explained, as well as the data collection and analysis system.