Management of Change: It’s About More Than Just Compliance…It’s About Best Practice

MOC Review Committee

For many safety professionals, Management of Change (MOC) tends to conjure up thoughts of OSHA’s Process Safety Management (PSM) Standard, EPA’s Risk Management Plan (RMP) Rule, or other complex regulations intended to help prevent major accidents or environmental releases involving hazardous chemicals.

While certainly required by numerous safety and environmental regulations, the value of MOC extends far beyond the realm of regulatory compliance. It is an invaluable tool for effectively coordinating and implementing virtually every aspect of your EHS management program, while simultaneously promoting greater transparency, accountability and employee engagement with your workplace EHS culture.

Unfortunately, MOC can be a somewhat confusing or even intimidating topic for many individuals — even those who consider themselves seasoned MOC practitioners. To help eliminate that confusion, we’ll provide some examples of how MOC can be applied to a wide range of EHS management activities, help you establish a common sense understanding of MOC principles and program components, and also discuss how the use of software products such as the VelocityEHS MOC Solution can help simplify and streamline management of change.

MOC Applications

Management of change is generally applied only when there are bona fide, substantive changes to processes, materials, equipment, technology, facilities, policies or personnel. MOC should not be used for simple replacements in-kind (RIKs) such as routine maintenance or other regularly scheduled EHS management activities, as this would likely lead to an unending cycle of change management that could quickly become unsustainable, and potentially damage your EHS culture. However, the range of projects and activities that MOC can and should be applied to is much broader than you might first realize.

Workplace Policies

To demonstrate this fact, let’s consider a scenario involving the implementation of a new uniform policy at an industrial manufacturing facility. Managers in one of the departments at the facility decided to issue uniforms to shop floor employees in an effort to improve the facility’s corporate image in the eyes of visiting stakeholders. Employees received their uniforms with little or no advance notice, and were informed that they were mandatory.

Almost immediately, employee complaints about the new uniforms started to roll in. Some employees complained about the comfort and breathability of the material in the hot environment of the shop floor. Workers who performed welding or other hot work learned that the uniforms were not flame-resistant, and perhaps most seriously, a machinist was almost severely injured when the baggy sleeve of the uniform was caught in the moving parts of a machine.

EHS Coordinators soon became aware of these uniform-related hazards and quickly intervened in order to replace the uniforms with a safer, more suitable alternative, but the damage had already been done. Employees were left feeling as if the decision to implement the uniform policy was made without their input, participation or consent, and that the department who spearheaded the project did not exercise sufficient care or concern for their safety in doing so. EHS Coordinators also felt excluded from the process, and lost confidence in top management’s commitment to workplace safety. In the end, the hasty implementation of a simple uniform policy ultimately resulted in unnecessary costs, and a lasting negative impact on the workplace EHS culture.

The root of the problem in this scenario was the issuing department’s failure to perceive the health and safety risks that could potentially arise from the uniform policy, and their subsequent failure to consult with both shop floor employees and EHS Coordinators in identifying and addressing those risks. Had the right people been involved in the policy implementation from the outset and sufficient planning taken place, facility managers could have successfully implemented the uniform policy while also reinforcing employee inclusion, engagement and participation in the facility’s EHS culture.

Facility Improvements

Another type of activity that can present multiple EHS risks would be facility improvement. Consider a scenario in which facilities managers decided to paint an interior corridor. Since they viewed this simply as a beautification project, facilities managers moved ahead with the project without recognizing the potential health and safety risks it could create, and therefore, without consulting EHS coordinators in order to identify and mitigate those risks.

Painting work began, and the previously unforeseen EHS risks soon became immediately apparent. Employees began to experience eye, skin and respiratory irritation accompanied by headaches and lightheadedness which ultimately resulted in several employees being sent home from work. EHS Coordinators soon became involved in this incident, and after preliminary investigation discovered that the paint used contained methyl methacrylate, a highly volatile and highly flammable substance that presents multiple physical and health hazards. In addition, OSHA also prescribes a permissible exposure limit (PEL) for methyl methacrylate that was potentially exceeded by the individuals most severely affected.

In the end, this seemingly harmless facility improvement project introduced health and safety risks to employees, and also created the potential for compliance violations, both of which could have had a substantial impact on the business in terms of financial liability, as well as lost time and productivity.

As with the uniform example, the facilities managers in this scenario did not initially even perceive that these changes had EHS aspects, even though they involved chemical storage and usage. They should have consulted with EHS coordinators to identify any potential health and safety risks, including any applicable regulations, prior to beginning the facility improvement project. EHS coordinators very well may have foreseen these risks, and helped develop hazard elimination strategies such as painting during off-hours, selecting a safer alternative paint product, procuring and installing temporary ventilation equipment, and recommending the use of hazard signage and PPE. Again, involving EHS Coordinators in the planning process for this project and using a system to identify and document the potential health and safety hazards could have avoided these risks.

The MOC Review Process

You may be asking, “So, what do I have to do to effectively manage change at my facility?” The answer to that question is relatively straightforward. All MOC reviews, whether they are for a permanent, temporary, or emergency change contain a basic set of components:

  • A description of the change, including technical specifications and business justification for the proposed change
  • An assessment of risks and potential impacts of the change on workplace health and safety
  • A description of any necessary modifications to operating procedures
  • Any necessary additional training for employees, contractors, or other individuals affected by the change
  • An anticipated timeframe required to complete the change
  • An established workflow for change implementation activities, including assigned individuals and approvers for each workflow stage
  • Written procedures for notifications and approvals at each change workflow stage
  • Any necessary updates to written process safety information (PSI)
  • Pre-startup safety review (PSSR) checklist items
  • Post-startup checklist, including evaluation criteria and follow-up actions to ensure successful change completion

MOC Challenges

All of these elements, and potentially others depending on the unique requirements of each individual change, must be effectively planned and documented to ensure successful project completion. Doing so requires identifying and communicating with the right departments and individuals to ensure that all potential risks are addressed. This ensures that the impact of the proposed change on other departments, facilities, supply chain partners and other stakeholders are accounted for. This can be a significant challenge for large facilities that are highly compartmentalized, and especially for companies with multiple facilities who are attempting to implement changes across their entire organization.

Paper-based MOC systems are simply not fast or flexible enough to meet the needs of a highly competitive marketplace where companies depend on the ability to adapt to a rapidly changing business environment. Using multiple disparate software applications to coordinate all of the necessary documentation, notifications, approvals, workflow management and follow-up is far too complex, and this complexity can ultimately discourage employees from applying MOC in scenarios where it is, indeed, beneficial to the business — not to mention such systems’ inherent potential for confusion and recordkeeping errors.

The most efficient way to coordinate your MOC activities is through the use of a single, dedicated software system that integrates all of the various tasks required for effective MOC, and which offers the flexibility to meet your needs in any change scenario you encounter.

Let VelocityEHS Help!

The VelocityEHS MOC Solution is the ideal system for organizations of any size to more effectively manage changes of all types, from first request through final implementation and follow-up. In fact, VelocityEHS has been consistently rated as the industry’s best MOC solution by leading third party EHS software analyst firm, Verdantix.

With the VelocityEHS MOC Solution, you can record, submit and manage change requests right from your mobile device, giving you the ability to document associated risks, as well as any necessary equipment, personnel, training or procedures, even when you’re out in the field. You can then quickly assign approvals and action items, and automatically distribute notifications to responsible personnel at each individual workflow stage. From there, you can easily build and deploy user-configurable PSSR and post-startup checklists to help you ensure a safe and successful change process, then instantly generate and publish reports to visualize change management activities across your entire enterprise.

With VelocityEHS, you get the ability to not just manage change, but master it. To see for yourself why we’re the industry leader in MOC software solutions, Request a Demo today!