The identification and mitigation of potential risks in the processing industries is at the core of process safety. To ensure that changes, no matter how minute, do not adversely affect safety, health, and environmental compliance, Management of Change (MOC) systems must be integrated.
The MOC system is a structured methodology that ensures that all changes are evaluated, documented, and communicated effectively. This, in turn, aims to minimise the likelihood of unintended consequences of processes that could lead to operational disruptions and/or potentially hazardous incidents.
In this short blog, we explore the fundamentals of MOC and examine a few of the common consequences that we have seen many organisations face. We hope that through this understanding, organisations can enhance their MOC practices and ensure safer, more efficient, and more compliant operations.
Management of Change in an Industrial Setting
From a process safety viewpoint, management of change is a systematic approach to addressing organisational, facility, and operational changes. Its purpose is to ensure that changes are implemented safely, seamlessly, and with minimal risk to people and the business.
Although some may view management of change as a blocker to project deliverability, it should be viewed as a cornerstone of process safety management – especially in major hazard industries.
Despite its significance, implementing and controlling management of change remains an industry challenge. If, for example, an operating manager decided to change one of the cleaning materials on-site due to a supply chain challenge or a cost-saving initiative, it may seem straightforward.
However, if the right questions are not asked of the right people, aspects may be overlooked. This may lead to potential risks and unpleasant surprises that jeopardise project delivery or even cause disasters.
Management of Change: a DSEAR Example
Consider changing a material used in your process from a DSEAR (Dangerous Substances and Explosive Atmospheres Regulations) perspective.
You will need to go through a screening process to determine whether the new material is flammable. If it is, then you have identified a dangerous substance.
DSEAR Regulation 5 states that no new work activity involving a dangerous substance shall commence unless an assessment has been made and the required measures have been implemented.
By recognising that these regulations apply to your organisation early on, you can take action to have a competent person assess your DSEAR risk. This assessment will help you understand potential zoning, safe distances, and the type of equipment needed.
Ignoring these steps, however, could lead to additional expenses and the need to relocate equipment to comply with regulations. Therefore, effective management of change is necessary to avoid repeated business issues.
Risk Levels
Change management processes should use risk-based logic. As a result, different and levels of change require different reactions that are reasonable and practical number of stage gates and approvals.
Because not all change is equal, a helpful approach is to use a scoring system to determine the impact of change early on.
Major Change
Major changes are likely to impact more stakeholders and require more approvals from higher decision-making authorities. These changes necessitate a more robust plan, often involving planning tools like Failure Modes and Effects Analysis (FMEA) or a “what-if” analysis to ensure complete coverage.
Minor Change
Minor changes may not require the same level of scrutiny due to the lower associated risk. These changes go through fewer stages and require fewer approvals.
Recorded Change
Recorded changes are typically updates within a process controlled by someone already responsible for that area. These changes will not significantly impact other departments. Maintaining a change log and communicating the changes made are useful practices.
This approach is also helpful for capturing minor adjustments, as it can be challenging to troubleshoot issues without a record of changes. A change log allows you to identify modifications in the system, which can explain differences in quality and safety results.
The robustness of your management of change system should correlate with the level of hazards and risks present. For significant hazards, such as large quantities of toxic or flammable materials or large-scale processing, the management of change needs to be extremely robust and thorough.
In a laboratory or pilot plant situation, changes can be more agile, but they will still require careful consideration. Regardless of the change, it should be reviewed by technical experts within your business to ensure informed decisions are made.
Length of Change
Different types of change will require different strategies. Everything from implementation to communication must be tailored to the type of change to be made.
Permanent Changes
Permanent changes are those that are intended to last more than six months. These changes are expected to remain in place, as the name suggests, permanently.
Temporary Changes
Temporary changes come with an expiry date. At the end of this period, a decision is made whether to revert to the original mode of operation or to make the change permanent.
Replacement in Kind
For older sites, particularly in the maintenance department, you may encounter “replacement in kind” equipment. This occurs when original equipment from the manufacturer is no longer available, and alternative spare parts are needed. A process ensures the alternatives meet specifications and do not increase risk.
Other management of change types can include bypasses, safeguards, and express changes. Express changes are useful for small, agile companies where experienced individuals can manage smooth changes. Larger organisations will typically have the infrastructure to implement comprehensive checklists to guide the change process.
The reason for categorising different types of change is to apply the appropriate process or procedure for each type. Since all changes are different, understanding the type of change will ensure that the correct steps are taken.
Roles in the Creation of Change
To effectively manage change, it’s essential to understand the level and type of change you, as a business, want to complete.
Companies that excel in management of change typically have a dedicated on-site resource to co-ordinate change management efforts. This resource tends to provide training to staff, updating and maintaining trackers to monitor the status of changes, while simultaneously ensuring that changes are properly documented, and lessons learned are shared.
Process Owners
Process owners are responsible for specific areas within the organisation. They are highly knowledgeable and should be consulted during changes that affect their areas of responsibility.
Change Owners
Change owners are the individuals driving change. Although they may come from different departments, it is their responsibility to document the change process, provide evidence, while overseeing the project through to completion. They must ensure that each stage of the change is reviewed thoroughly. Change owners liaise with process owners and may seek advice from coordinators to ensure the change is implemented smoothly.
Having clear roles and responsibilities will help streamline the change process and ensures that all necessary steps are taken to manage changes effectively.
Change Stages
The stages that change go through will vary depending on the level and type of change being implemented. Major change, for example, will require additional stages to ensure all aspects are covered and risks are minimised, whereas low-risk changes can follow a more streamlined process.
Approval to Plan Stage
In this stage, a change will have been requested, and the determination of scope, impacted areas, and required actions will be discussed. This involves creating a project plan and identifying who will be responsible, accountable, consulted, and informed. Once you have approval to plan, you can proceed to the planning stage.
Planning Stage
During this stage, risk assessment tools can be used to understand and plan actionable items for implementing the change. A detailed plan outlining how the change should be executed safely is put together and agreed upon.
Approval to Implement Stage
The plan for approval should also include how the change will be carried out safely. Once approved, you can then proceed to the implementation change.
Implementation Stage
At this stage, the equipment is purchased, installed, and commissioned. There are frequent meetings with stakeholders, so those impacted by making the changes are well-informed. Any unexpected changes to the plan go through documented change management.
Closing Stage
Before releasing the change, whether it involves new equipment or a new process, you must go through the closing stage. This will include the approval to run and hand over the change. You should ensure that any necessary training is provided, the SOP are written, and key performance indicators (KPIs) are established to measure the change success.
Documentation
Once you are satisfied with the progress of the change, you must document the lessons learned. This documentation helps future change-makers improve their processes, while contributing to the continuous improvement mindset of the business.
Systems and Feedback
Clear systems and effective feedback mechanisms (i.e., change logs) are useful for monitoring the status of changes: how many are open, how many are closing, what stages they are in, and what resources are needed to close them. Without proper monitoring, you may end up with a backlog of incomplete changes and the risk of misinformation on process availability.
It’s important to monitor the impact of changes to see if they meet goals and improve processes equipment manuals with instructions should be kept up to date. For example, legacy equipment manuals may have bearing greasing intervals like every 100 hours. The guidelines for proper maintenance must be followed and documented.
Conclusion
Effective management of change (MOC) is a necessary element in ensuring that modifications to processes, equipment, personnel and the organisation are systematically managed to mitigate risks and prevent adverse effects on safety, health, and environmental compliance.
By implementing robust MOC systems, organisations can improve efficiency, and foster a culture of continuous improvement.
Sigma-HSE can provide bespoke Management of Change solutions for your organisation’s needs. Sigma-HSE can also provide consultancy solutions including DSEAR training, policy, procedure, gap analysis and management support. Sigma-HSE can provide bespoke PHA solutions including QRA, FMEA, LOPA, FTA, ETA, and BOWTIE analysis.
