Organizational change (i.e., any change in position or responsibility in an organization, structural organizational change, or an organizational policy or procedure that affects process safety) is a regular part of doing business. People retire, start new jobs, get promoted, transfer, or change positions – but organizations still must ensure they operate safely. Management of Organizational Change (MOOC) is how companies meet the obligation to operate in compliance with safety regulations and ensure people go home to their families each night.
Effective MOOC processes and procedures prepare, support, and guide individuals and teams through changes affecting the entire organization (e.g., de-layering, introducing new layers, functional consolidation, changes in reporting relationships). MOOC must also ensure that all safety-critical tasks and decisions are carried out by competent staff, that staff are not overloaded, and that these tasks are not omitted because of the organizational change. In other words, for MOOC, the key issue is whether the change impacts the organization’s ability to implement process safety-critical tasks or to control process hazards; if not, then from a process safety perspective, it is not an organizational change.
Figure 1 – OESuite® MOOC Workflow
During organizational changes, it is important to consider the implications of the revised organization and the potential safety impacts during the transition. Clear criteria about competency levels should be available and verified before the organizational change takes effect. Task mapping can help you understand the complete impact of a change and ensure that you have all the bases covered.
Another critical aspect of MOOC is Risk Assessment. The MOOC risk assessment needs to consider the potential process safety impacts under all foreseeable conditions and scenarios, including:
- All activities required to operate and maintain the facility in a safe condition, such as operations, maintenance, and contractor activities
- All activities required for process safety management, such as PHA, mechanical integrity, incident and near-miss investigations, and MOC
- Effective emergency response
Once the risk assessment is completed, the findings should be summarized, and an action plan should be developed to address the RA findings. This action plan should be part of an overall implementation plan for the change.
Another area of consideration is that shutdowns, turnarounds, and startups, which present special challenges for process safety. Special provisions or policies should be implemented to accommodate additional staffing during these critical time periods. Changes to these special staffing policies should be considered an MOOC activity.
Organizations should also invest time and resources into creating, implementing, and enforcing MOOC policies and procedures.
- An MOOC policy should ensure that any changes are properly risk-assessed and that minimum levels of competence and staffing for safety-critical activities are defined and maintained within safety-critical roles. The policy should state the organization’s principles, commitment, work process, and accountability, and commit to proportionate consideration of all organizational changes, large and small, whether or not they appear to impact safety.
- The MOOC procedure should clearly define an organizational change (e.g., working condition changes, personnel changes, task allocation changes, hierarchy changes, policy changes, etc.).
Policies and procedures should apply to all personnel in Process Safety Critical (PSC) Positions (i.e., employees and contractors who, if they weren’t present/available as resources to the operating process or did not meet established standards, would raise the risk of serious process incidents).
Figure 2 – Operational Sustainability® MOOC Procedures & Sample Content
Operational Sustainability® can assist organizations with their MOOC policies and procedures through the OESuite® Organizational and Personnel Change Module and pre-configured technical content for MOC and MOOC to help organizations maximize the impact of MOC and MOOC but minimize the time burden to ensure changes are made without exposing an organization to additional risk.