We have all been there… the auditor identified several “physical changes” during their walk-thru of the process, and when it comes time to audit the MOC element, they begin asking for completed MOCs (and PSSRs). And like everyone before us and mostly after us, we will have made changes that needed a MOC, but we failed to perform one. This leads to an audit finding and much consternation among the facility personnel as to how they address the audit finding. For me, it is a three-stage action plan: