Improving Process Safety Performance By Leveraging Management of Organizational Change

Management of Organizational Change (MOOC) addresses the process of managing any change in position or responsibility in an organization or any change to an organizational policy or procedure that affects process safety—a vital component of an effective Process Safety Management (PSM) program. MOOC touches almost everyone in an organization, as change is in everything we do, and critical to sustaining and improving an organization.

Despite the critical nature of MOOC, most companies focus their processes and governance around facility and technology change because of regulatory compliance requirements such as OSHA 1910.119, EPA RMP per 40 CFR Part 68, or a similar regulatory driver like API RP 75. This leaves MOOC often overlooked or superficially addressed with a checklist driven by HR or operations leadership. Some organizations will even go 6-12 months, or longer, without addressing Process Safety Critical (PSC) roles in their plants, despite the subtle gaps in capability and the elevated risks the delays create.

During a recent EH&S conference in June 2025, 26 participants mainly from chemical and oil and gas industries shared their views regarding the maturity of their MOOC work practices. When asked if their companies have a formal MOOC program in place that went beyond a checklist or informal work practices, no one raised their hand—this corroborated feedback received at previous conferences when this topic was presented. It also provides additional insight into the following questions posed and subsequent feedback received:

Question 1: ‘Do you review critical PSM skills at least annually to make sure you have addressed gaps?’

• 58% answered ‘no’
• 23% answered ‘yes, and action is taken to address skills, knowledge, or experience gaps both now and looking toward the future’
• 11% answered ‘yes, but our actions are very short-term focused with little attention to medium or longer-term, anticipated gaps’
• 4% answered ‘yes, but rarely are actions taken as a result of the review’
• 4% answered ‘yes, but the reviews are rarely more than just our senior site leader and the HR leader having a private conversation with little, if any, broader engagement’ 

Question 2: ‘When an individual exits the organization who possesses critical PSM skills, knowledge, or experience, what does that individual’s supervisor usually do to fill the vacancy?’

• 52% answered ‘identifies a replacement (via internal postings, external hiring, or via networking) without regard to PSM critical skills that the candidate possesses’
• 20% answered ‘meets with the departing individual to identify the specific skills, knowledge and capabilities that are at risk of being lost. Selects a candidate that has the potential to possess these attributes within a short period of time’
• 20% answered ‘appoint a temporary, interim replacement to gauge whether this individual may be satisfactory, without making a commitment to develop the individual’s PSM critical skills and abilities’
• 8% answered ‘follows the most recent Succession Planning documents that may or may not consider the PSM critical skills possessed by the potential candidates’

Question 3: ‘What is the biggest barrier in your organization for implementing Management of Organizational Change when there is a large, multi-person change?’

• 35% answered ‘the change (i.e., restructuring) is effective immediately and there is no time allowed to evaluate the impact on PSM skills’
• 30% answered ‘HR is coordinating the multi-function change, and they are not aware of the PSM critical skills that some of the impacted individuals possess’
• 26% answered ‘no PSM Critical Skills reviews are being performed and thus, no consideration is given to MOOC when the change is contemplated or planned’
• 9% answered ‘the change is considered too confidential to share with those who might have a role in executing MOOC requirements’

Operational Sustainability^® (OS) has observed that less than 5% of companies have a formal structure that addresses critical components of MOOC, and the survey responses confirm that pattern. While there are many reasons why MOOC hasn’t been formalized in the hydrocarbon processing and process industries, the data also indicates that organizations today operate in disjointed and siloed software for training and compliance, making it challenging to gain holistic insights into their organizational performance.

Operations and compliance leaders frequently face challenging decisions that impact safety, production, costs, and people, and often without the benefit of formal MOOC to mitigate the risks that come with those decisions. Companies need more effective work processes and supporting governance structures (i.e., policies, standards, and procedures) to empower their leaders to make the right decisions. With the OESuite^® Organizational & Personnel Change Module, organizations can leverage an interoperable software solution to organize, evaluate, and share MOOC data seamlessly across key departments, creating a structured way to approach critical decisions.

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