What is Management of Change?
Posted on February 28, 2023 | in Operational Risk
Many people might read the phrase “management of change,” and pretty quickly convince themselves that they understand what it means – managing any changes made. But, what does it mean to actually manage a change?
What is Management of Change?
Management of Change (MOC) is the principle of properly assessing, addressing and controlling the impacts of any proposed changes to the workplace – ideally, before the changes take place. MOC done well is like planning for the “butterfly effect,” how one seemingly small thing can have much larger effects, and it’s considered a central part of safety management.
Following MOC means that facility EHS leaders assess the possible impacts from a change made to the workplace, identify negative outcomes and put controls in place to stop those negative outcomes from happening.
Failing to assess the impacts that proposed changes would have on the workplace puts the facility at risk. One change, and one unexpected thing happening as a result, could end up causing explosions, fires, and/or catastrophic releases that affect the surrounding environment, water and the health, safety and wellness of employees. In fact, failures to properly assess and control risks associated with planned changes have contributed to some of the worst industrial disasters in history, including the infamous 1984 release of methyl isocyanate (MIC) gas at a Union Carbide plant in Bhopal, India. Investigations after the accident found that several improperly planned and controlled changes, such as the removal of piping from a flare tower to burn MIC gas and the deactivation of a vent gas scrubber, led to or failed to mitigate the deadly outcome of the chemical release.
What does MOC mean per OSHA?
OSHA’s Process Safety Management (PSM) Standard has a regulatory requirement for covered facilities to have an established MOC procedure, to protect employees. The EPA has a similar rule called the “Risk Management Planning Rule,” which is designed to manage risk to the surrounding community.
Both rules require established procedures for management of change. For facilities that are subject to MOC, the stakes are too high not to have MOC procedures. The potential is significant for spills, fires, explosions or air and water releases that can impact human health and the environment. There’s a connection to chemical management here too, because storage of specifically listed chemicals above threshold quantities creates Process Safety Management obligations, so EHS managers need to understand their chemical inventory and which processes are covered by PSM and/or Risk Management Planning.
Why use MOC?
Like any other principle of EHS, and specifically risk management, everything in MOC comes down to keeping people safe and avoiding major incidents. Any time a change occurs, you want to ensure that nothing newly introduced is not introducing additional risk. If it is, you need controls in place to counter it.
Every time a change is made to a process, people or procedures, an MOC assessment should be completed. From a PSM standpoint: Changes to or introduction of hazardous processes will need to be reassessed for risk. Any new equipment needs to be explored with regards to “what happens if x happens?” Based on data from the Chemical Safety Board, the lack of an MOC process is a leading root cause of incidents.
How does MOC relate to Operational Risk?
One type of change might be adding a process you didn’t have before. Another type of change involves physical rearrangement of the facility or equipment. If you rearranged the facility in a way that could impact safety, it might change evacuation routes. If you change the proximity of pieces of equipment to each other, you might introduce hazards. There should be a procedure in place for the right people to review the proposed changes, identify the hazards and risks, determine and implement appropriate controls that need to be in place before the change is made.
In a nutshell, when things change without being assessed – even potentially “small” things that seem inconsequential or unrelated to other things – it increases an organization’s risk level. MOC failure incidents happen much more often than people realize. Not all incidents reach a threshold to seem “newsworthy,” but they happen every day.
Here’s an example of a situation that needed MOC.
A potential change does not need to be process-related to merit review and control through an MOC process. Here’s an example that demonstrates this point.
A company decides that they want to repaint their lobby and hallways to impress the big executives who’ll be visiting next year. The site manager picks a paint color – yet another shade of off-white—and doesn’t think to alert the corporate EHS manager because it’s just paint.
However, as employees start painting the walls, many start to feel light-headed and nauseous. What the site manager and employees didn’t know was that the paint being used included methyl methacrylate, which is a volatile organic compound (VOC).
If the site EHS Manager had been alerted about this change to the paint in the lobby and hallways, they would have looked up the paint’s Safety Data Sheet and read its hazards and symptoms of exposure, which are dizziness and nausea. The EHS manager would have provided appropriate Personal Protective Equipment (such as respirators) and/or, set up additional ventilation in the work areas, and to pause work for employees reported symptoms of exposure.
Because this change to the paint color wasn’t managed well, it put employees at risk. If there had been a conversation with the EHS manager before work started, the associated risks would have been assessed and the right measures taken to keep the employees safe.
Again, this is an important conversation that many people don’t perceive would need to review as part of their MOC process. Since the changes aren’t process-related, management may overlook EHS risks.
Recognizing that MOC procedures are imperative to operations is key to preventing incidents. Whether you’re moving equipment around in a facility, adding new processes or chemicals could have an impact on safety. MOC is especially important if you’re making changes to any process involving flammable or combustible, toxic, or corrosive materials or oxidizers. With changes that involve products that are highly reactive, the right controls need to be in place before using those products.
Why isn’t MOC used more often?
There’s a disconnect in people’s minds between proposed changes and whether they’re connected with EHS. In the example above, the change made was just a paint color, so the people involved in the paint selection didn’t think to alert the facility EHS manager, but the paint ended up as a hazard for employees.
When changes aren’t assessed and don’t get controlled there can be negative outcomes – like harm to workers, the community, or the environment, and potentially impact the future of the business. Facility managers need to start widening the lens regarding workplace risks and learn to recognize more planned changes that require MOC. They need to expand their understanding of possible outcomes, and to put controls in place that will ensure the safety of employees.
Don’t Just Manage Change, Master It.
VelocityEHS Management of Change capabilities are designed to streamline operational change processes with comprehensive workflow support and visibility.
When you’re faced with complex process safety management challenges, you’ll appreciate the simplicity of the VelocityEHS approach even more. You have enough on your plate without having to spend time coaxing a clunky, complicated MOC system to provide the control and visibility your role requires. We help you solve challenges efficiently and effectively. And if you’re currently managing your processes with a paper system or spreadsheets, you’ll be amazed at how much pressure an effective cloud solution can take off, giving you the freedom to focus on MOC. It’s one reason VelocityEHS is the industry leader with more than 10 million users.