Management of Change for Process Safety

Problem Statement

The way change is managed is critical as businesses both large and small rethink how they can productively operate in tough economical circumstances.    From a cost-savings perspective, there are larger upfront costs associated with buying new machinery rather than modifying existing machinery.  It may be cheaper to purchase personal protective gloves with little impact protection than re-purchasing impact gloves with high impact resistance which have been utilized for the past 15 years. 

Time also plays a large part in cost savings due to the fact less money is spent when work is done faster, but this may be at the expense of someone’s exposure to various risks.   These decisions, and many others, all shape the importance of having an effective and efficient management of change program because these choices affect the most valuable resource of any company, the worker who has to live with these choices.  

What is Management of Change (MOC)?

Management of Change is a process for evaluating and controlling modifications to facility design, operation, organization, or activities – prior to implementation[1].  In all cases it’s intended to protect the worker or general public from being exposed to a hazardous condition or environment, protect the environment, and prevent significant business interruptions by administratively creating documents that seek review and approvals. Thus, a MOC program will evaluate potential health and safety impacts for any change.   Here are some examples of when to initiate a MOC  program as they can be overlooked[1]. 

·         Process equipment changes such as equipment re-configuration

·         Process control changes such as computerized systems, including logic software

·         Site infrastructure changes such as fire protection or roads

·         Operations and technology changes such as the introduction of a new chemical on site

·         Changes in inspection, testing, and preventative maintenance such as lengthening an inspection interval.

·         Changes in procedures such as standard operating procedures

·         Organizational and staffing changes such as reducing the number of operators on a shift

·         Policy changes such as changing the amount of overtime permitted

Various governmental agencies, including OSHA and the EPA, all regulate the need for a MOC program to be integrated into business operations.  In addition, historical evidence proves that without an effective MOC process the impacting results can be catastrophic.  But even with the need very apparent, many companies still have failed to produce an effective MOC system[2].  Some companies lack maturity due to the lack of resources that can accommodate the quantity of change at any given moment while others struggle due to a lack of protocols that address meeting MOC requirements.  This stresses the need for companies to induce a safety culture as the foundation for implementing a MOC system.