Everything you need to know about management of change
What is management of change?
The term “management of change” refers to the process of making changes to existing facility design, operations, organization, or activities in a way that won’t introduce new hazards or increase the risk of existing hazards. The goal is to ensure employees, the public, or the environment won’t be negatively affected by the proposed adjustments. This involves a review and authorization process for evaluating proposed changes before implementing them. It also includes steps to notify potentially affected personnel of the changes.
Why do I need to care about management of change?
If management of change processes aren’t followed, employees can be seriously injured or killed. In less extreme cases, management of change processes are simply used to ensure that changes are documented and well understood before they’re made.
In the case of process safety management (PSM) requirements, there are hefty fines associated with not following and documenting a management of change process. These requirements are laid out by 29 Code of Federal Regulations (CFR) 1910.119(l).
What are the OSHA management of change requirements?
The Occupational Safety and Health Administration (OSHA) only requires management of change tracking for companies that fall under PSM regulations. If your company doesn’t, then you don’t need to worry about them for regulatory reasons. However, such procedures to manage change are a best practice, as they can prevent changes that may negatively impact employees or production.
PSM requirements
The management of change (MOC) section of the PSM standard requires employers to develop and implement written procedures to record and manage all changes associated with chemicals, technology, equipment, procedures, or facilities covered by PSM. They must include descriptions of the technical reason for the change, the impact on health and safety, any modifications made to procedures, the time necessary for the change, and the authorizations required to make the change. As stated earlier, any employee who may be affected by the change must also be informed and trained on the change. Even temporary changes must be documented as well as the time limit and reason for the change. If your PSM facility is ever audited by OSHA, you’ll need to produce all of the documentation, approvals, and training records for your MOCs.
What tools exist to make management of change easier?
Many companies rely on paper approval methods or document-sharing programs sent via e-mails. Although this method can work, it isn’t easy to track and may make managing a program more difficult. Ideally, MOC should give you a transparent, easily accessible change request system. This system should ensure no changes can be made without all the risks and controls identified, or without proper authorization. Generally, it makes sense to use a program specifically designed to establish, track, and manage your MOCs. MOC software like this is designed to make management of change easier and save your company time and money. It also ensures you don’t have to worry about losing track of paperwork or approvals.
Multifacility cloud-based solutions offer the best value to companies with change management needs as they enable easy access to the correct personnel and offer recordkeeping in case of review or audit. They ensure the MOCs are available anywhere at any time and give companies mobile capabilities so they aren’t restricted to their desk.
How to create a MOC
Management of change can differ from company to company, but an effective process makes all the difference. Most organizations have written procedures detailing how management of change will be implemented. These procedures apply to work that is considered not to be replacement in kind. An MOC review form is used to document the results of the review process and any documents providing additional information about the change are attached to the form.
Here are the steps that should be taken:
- Create a detailed change request
- Make the request easy to access
- Notify approvers for preapproval
- Once preapproved, notify reviewers
- Once reviewed, follow your pre-start-up review (PSR) checklist (if required)
- Notify approvers for final approval
- If at any step isn’t approved, make the necessary changes and revert to step 3
After a change is approved, be sure that all affected employees are trained on and understand the change and how it affects their work before the change is made. Perform training regularly to prevent incidents and injuries surrounding your process.
