Formal Management of Change (MOC) programs help power generation and HVDC facilities prevent fire protection gaps that can occur through modifications, expansions, or equipment substitutions over time. Unreviewed changes to equipment, layout, or procedure can undo years of careful fire protection planning. As equipment is upgraded, layouts shift, and procedures evolve, a thorough MOC program helps ensure fire safety keeps pace. NFPA 850, Standard for Fire Protection for Electric Generating Plants and High-Voltage Direct Current (HVDC) Converter Stations, 2026 Edition, §5.4.3, requires that: “…a management of change program shall be implemented to ensure that the appropriate individual(s) with fire protection responsibility is made aware of new construction, modifications to existing structures, changes to operating conditions, and other actions that could impact the fire protection of the plant.” A basic MOC program would typically include, but may not be limited to, the following elements: 

A brief summary of each element of an MOC program is provided below.

Screening

The MOC process typically begins with a screening review to determine whether a proposed change should be pursued. Screening may consider site needs, economics, technical feasibility, regulatory requirements, insurance requirements, and similar factors. This step typically includes an input form completed by the change initiator and review by a committee that includes management and technical subject matter experts. Fire Protection Review Once a decision is made to proceed with a change, the facility should assess the potential impact on fire protection. This assessment should be performed by an individual with fire protection expertise and familiarity with the facility. The review should identify potential impacts to, or necessary modifications of, the facility’s fire protection features, including:

• Changes to fire barriers

• Changes to fire detection systems

• Changes to fire suppression systems

• Installation of structures that could impede firefighting efforts

• Installation of systems or equipment that introduce a new hazard to the facility

Design

The design phase should begin by identifying all applicable codes and standards. For example:

• Changes to, or installation of, a sprinkler system would require consideration of NFPA 13, Standard for the Installation of Sprinkler Systems

• Installation of a new transformer could require a water spray system in accordance with NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection

• Changes to, or installation of, fire alarm and detection systems would require consideration of NFPA 72, National Fire Alarm and Signaling Code

• Installation of a battery energy storage system would require consideration of NFPA 855, Standard for the Installation of Stationary Energy Storage Systems

Industry codes and standards identify design, acceptance testing, and periodic inspection, testing, and maintenance requirements. During this phase, necessary drawings, calculations, procedures, software, and related documentation should be identified and developed. The design phase is also when the project team is formed, stakeholders are identified, and project schedules are developed.

Training Requirements

After the design is partially or fully developed, the facility should assess whether training is needed for system operation and inspection, testing, and maintenance (ITM) activities. Construction/Installation The construction/installation phase of a change may involve:

• Impairing the fire protection water systems to allow new connections

• Impairing fire alarm or detection systems in an area during hot work activities to prevent false alarms

• Breaching fire barriers to run cables, conduit, or piping systems

• Hot work activities

• Integrating software systems into existing plant systems

Acceptance Testing/Commissioning

When an existing system is modified or a new system is installed, acceptance testing is necessary to verify that the system has been installed properly and will function as designed. This may involve:

• Trip testing fire suppression systems

• Testing alarm-initiating devices, notification appliances, fire alarm control panels, and related components

A written acceptance test plan should be developed in accordance with applicable codes and standards to document whether acceptance testing was successful and to identify appropriate corrective actions for any deficiencies. Refer to NFPA 3, Standard for Commissioning of Fire Protection and Life Safety Systems, for additional information on commissioning.

Documentation and Records Management

Once the change has been installed and all documentation has been updated as-built to reflect field changes made during installation, the documentation should be turned over to the owner and incorporated into the owner’s record system. This is an area where many change projects fall short. The MOC process should include a document control plan that ensures documentation is saved in a format that is easy to locate and retrieve for future personnel, owners, operators, or the Authority Having Jurisdiction (AHJ).

Please contact your AEGIS Property Loss Control professional with any questions about this topic. This Quick Tip is not intended to be a comprehensive description of a detailed MOC program. It does, however, provide a basic overview that can serve as a starting point for developing a company - or site-specific MOC program.

For additional guidance on MOC, see the Center for Chemical Process Safety’s (CCPS’s) Guidelines for Management of Change for Process Safety.

The referenced NFPA Codes and Standards are available at: https://www.nfpa.org