Management of Change (MOC) has been a regulatory requirement for more than 20 years, yet companies continue to struggle to implement and sustain it. While not always obvious, many process safety performance issues can be traced back to the failure of a central aspect of a Management of Change program – ineffective control of personnel changes throughout the organization and across many key roles that impact process safety. Sites need to maintain a specific level of process knowledge and experience across the organization as people change. Failure to do so can put people, facilities, and organizations at risk.
The core issues are:
- Recognizing what constitutes a "Change"
- Developing an effective management system for MOC
- Getting cultural buy-in so that personnel effectively participate in MOC
- Dealing with the volume of data created by the MOC process
- Recognizing the breadth of change that an organization must address in order to maximize both safety and operational benefits, which goes well beyond regulatory compliance drivers
- Effectively recognizing and managing Personnel and Organizational change
Why Do Companies Need to Care About Management Of Organizational Change (MOOC):
Incidents linked to personnel or policy changes that have impacted Process Safety Management (PSM) covered processes have led to an emphasis on addressing MOOC. One core tenant of MOOC as it applies to personnel is to review the capability of and promotability of personnel assigned to hazardous processes at least once per year.
If your organization deals with hazardous processes, these key points should be a part of every evaluation process for changes made in personnel and policies (helping you effectively follow MOOC):
- Organizational restructuring
- Promotions
- Retirements
- New Hires
- Terminations
- Resignations
- Long-term disabilities
- Inter- and intra-plant transfers
- When any of the above may affect Process Safety Management (PSM) at the plant level and would therefore trigger a PSM MOC procedure
Regulatory issues:
- An OSHA Memorandum from 3/31/09 reinforced that some organizational changes, such as changes resulting from mergers, acquisitions, reorganizations, staffing changes, or budget revisions, may affect Process Safety Management (PSM) at the plant level. Some examples include:
- Personnel changes, including changes in staffing levels, staff experience, or contracting out that directly impact PSM covered processes; and
- Policy changes such as budget cutting that impact PSM covered processes
- In other words, if organizational changes necessitate changes to process chemicals, technology, equipment, procedures, or facilities, an MOC procedure would be required to ensure that resulting changes are managed and implemented in a manner that assures continued safe operations
- Clear exemption: Organizational changes that have no relationship to plant-level PSM processes, as in the case of changes to corporate or administrative personnel whose duties do not relate to operations or maintenance functions, do not trigger PSM MOC procedures
Why does good MOOC matter?
- Provides a solid base for decisions that can affect process safety
- Safe operations require well-trained and experienced personnel, including operating, maintenance, and contractor personnel
- Loss of minimum levels of experience and knowledge through personnel movements and organizational changes potentially invalidates prior hazard assessments that were based on knowledgeable people being present and in charge
How does your organization deal with the issues surrounding effective Management of Change and Management of Organizational Change?