Unit VI Article Critique

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Program Development Peer-Reviewed

Management ofC

Examples From Practice By Fred A, Manuele

M anagement of change (MOC) is a commonly used technique. Its purpose is to:

•Identify the potential consequences of a change.

•Plan ahead so that counter actions can be taken before a change occurs and continuously as the change progresses.

With respect to operational risks, the process ensures that:

•Hazards are identified and analyzed, and risks are assessed.

•Appropriate avoidance, elimination or control decisions are made so that acceptable risk levels are achieved and maintained throughout the change pro- cess.

•New hazards are not knowingly in- troduced by the change.

•The change does not negatively af- fect previously resolved hazards.

•The change does not increase the severity potential of an existing hazard.

This process is applied when a site modifies technology, equipment, fa- cilities, work practices and procedures, design specifications, raw materials, or- ganizational or staffing situations, and standards or regulations. An MOC pro- cess must consider:

•safety of employees making the changes;

•safety of employees in adjacent work areas;

•safety of employees who will be en- gaged in operations after changes are made;

•environmental aspects; •public safety;

Fred A. Manuele, P.E., CSP, is president of Hazards Limited, which he formed after retiring from Marsh & McLennan where he was a managing director and manager of M&M Protection Consul- tants. His books include Advanced Safety Management: Focusing on ZIO and Serious Injury Prevention, On the Practice of Safety, Innova-

•product safety and quality; •fire protection so as to avoid prop-

erty damage and business interruption. OSHA's (1992) Process Safety Man-

agement Standard (29 CFR 1910.119) requires that covered operations have an MOC process in place. No other OSHA regulation contains similar re- quirements, although the agency does address MOC in an information paper (OSHA, 1994). Also, this subject is a requirement to achieve desig- nation in OSHA's Voluntary Protection Programs.

Establishing the Need Three studies establish that

having an MOC system as an element within an operation's risk management system would serve well to reduce serious injury potential. This author reviewed more than 1,700 incident investigation reports, mostly for serious in- juries, that support the need for and the benefit of an MOC system. These reports showed that a significantly large share of incidents resulting in seri- ous injury occurs:

•when unusual and non- routine work is being per- formed;

•in nonproduction activities; •in at-plant modification or

construction operations (e.g., replacing an 800-lb motor on a platform 15 ft above the fioor);

IN BRIEF •Studies and statistics indi- cate that an effective man- agement of change (MOC)/ prejoh planning compo- nent within an operations risk management system reduces the potential for serious injuries. •Specific guidelines from practice can help SH&E professionals initiate and utilize an MOC system. •Real-world examples of MOC systems in place for other than chemical opera- tions are discussed (and availahle through PS Extra). SH&E professionals can reference these examples when developing an MOC system to suit particular operational needs.

fions in Safety Management: Addressing Career Knowledge Needs, and Heinrich Revisited: Truisms or Myths. A professional member of ASSE's Northeastern Illinois Chapter and an ASSE Fellow, Manuele is a former board member of ASSE, NSC and BCSP.

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Having an effective

IVIOC sys- tem wiil

reduce the probabiiity of serious

injuries and fataiities.

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•during shutdowns for repair and maintenance, and startups;

•where sources of high energy are present (elec- trical, steam, pneumatic, chemical);

•where upsets occur (situations going from nor- mal to abnormal).

Having an effective MOC system will reduce the probability of serious injuries and fatalities occur- ring in these operational categories.

A 2011 study by Thomas Krause and colleagues produced results that support MOC systems as well. Seven companies participated. Shortcomings in prejob planning, another name for MOC, were found in 29% of incidents that had serious injury or fatality potential. Focusing on reducing that 29%, a noteworthy number, is an appropriate goal. (Data based on personal communication. BST is to pub- lish a paper including these data.)

In personal correspondence, John Rupp of United Auto Workers (UAW) confirmed the continuing his- tory with respect to fatalities occurring in UAW-rep- resented workplaces. According to Rupp, from 1973 through 2007, 42% of fatalities involved skilled- trades workers, who represent about 20% of UAW membership. Rupp also reported that from 2008 through 2011, 47% of fatalities involved skilled- trades workers. These workers are not performing routine production jobs. They often perform unusu- al and nonroutine work, in-plant modification or construction operations, shutdowns for repair and maintenance, start-ups and near sources of high en- ergy. An MOC (or prejob planning) system would be beneficial for such activities.

Assessing the Need for a Formalized MOC System Studying an organization's incident experience

and that of its industry can produce useful data on the need for a formalized iVIOC system. Workers' compensation claims experience can be a valuable resource as well.

To develop meaningful and manageable data, an SH&E professional should execute a computer run of an organization's claims experience covering at least 3 years to identify all claims valued at $25,000 or more, paid and reserved. If experience in other organizations is a guide, this run wül likely encom- pass 6% to 8% of the total number of claims and 65% to 80% of the total costs.

Data analysis should identify job titles and inci- dents that have occurred during changes, and indi- cate whether a formalized MOC system is needed. Industry experience that may be available through a trade association or similar industry group also should be reviewed. Finding that few incidents resulting in serious injury occurred when changes were being made should not deter an SH&E pro- fessional from proposing that the substance of an MOC system be applied to particular changes which present serious injury potential.

Experience Implies Opportunity To test whether personnel in operations other

than chemical sites had recognized the need for and developed MOC systems, the author queried

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members of ASSE's Management Practice Special- ty. The response was overwhelmingly favorable, and the number of example documents received was more than could be practicably used.

Examples received demonstrate that manage- ment in various operations has recognized the need for MOC systems. Eight systems selected from this exercise and two previously available are presented as examples in this article. Due to space restrictions, of the 10, one is printed on p. 41, and all are posted at www.asse.org/psextra.

These select examples show: •the broad range of harm and damage categories

covered; •similarities in the subjects covered; •the wide variation in how those subjects are ad-

dressed. These examples reflect real-world applications

of MOC in nonchemical operations. They display how such systems are applied in practice.

History Defines Needs & Difficulties of Application At least 25 years ago, the chemical and process

industries recognized the importance of having an MOC process in place as an element within an op- erational risk management system. That awareness developed because of several major incidents that occurred when changes were taking place.

In 1989, Center for Chemical Process Safety (CCPS) issued Guidelines for Technical Manage- ment of Process Safety which included an MOC element. In 1993, Chemical Manufacturers Asso- ciation published A Manager's Guide to Implement- ing and Improving Management of Change Systems.

In 2008, CCPS issued Guidelines for Management of Change for Process Safety, which extends the pre- vious publications. From the preface:

The concept and need to properly manage • change are not new; many companies have implemented management of change (MOC) systems. Yet incidents and near misses at- tributable to inadequate MOC systems, or to subtle, previously unrecognized sources of change (e.g., organizational changes), con- tinue to occur.

To improve the performance of MOC sys- tems throughout industry, managers need advice on how to better institutionalize MOC systems within their companies and facilities and to adapt such systems to managing non- traditional sources of change, (p. xüi)

Note that incidents and near misses (near hits) attiributable to inadequate MOC systems continue to occur. Also, organizational changes are being recognized as a previously unrecognized source from which MOC difficulties could arise. As noted by CCPS (2008), "Management of change is one of the most important elements of a process safety management system" (p. 1).

MOC Requirements in Standards & Guidelines Several standards and guidelines require or sug-

gest that an MOC process be instituted, including:

•ANSI/AIHA ZlO-2005, American National Standard for Occupational Health and Safety Man- agement Systems, which requires that an MOC process be implemented (Secfion 5.1.2).

•BS OHSAS 18001:2007, Occupational Health and Safety Management Systems Requirements, which states, "For the management of change, the organization shall identify the OH&S hazards, and OIÍ&S risks . . . prior to the introduction of such changes" (Section 4.3.1).

•OSHA comments on change analysis in its Safety and Health Management System eTool: Worksite Analysis.

Anytime something new is brought into the workplace, be it a piece of equipment, differ- ent materials, a new process or an entirely new building, new hazards may uninten- tionally be introduced. Any worksite change- should be analyzed thoroughly beforehand because this analysis helps head off prob- lems before they develop.

Provisions that require MOC systems may have different names. For example. Section 7.3.7 of ANSI/ASQ Q9001-2000, Quality Management Systems: Requirements, is titled "Control of design and development changes." It states:

Design and development changes shall be identified and records maintained. The changes shall be reviewed, verified and vali- dated, as appropriate, and approved before implementation. The review of design and development changes shall include evalua- fion of the effect of the changes on constituent parts and product already delivered. Records of the results of the review of changes and any necessary actions shall be maintained.

The MOC Process As with all management systems, an adminis-

trative procedure must be written to communicate what the MOC system encompasses and how it should operate. The system should be designed to be compatible with the organizafion's and indus- try's inherent risks; management systems in place; organizational structure; dominant culture; and ex- pected workforce participafion.

Although brevity is the goal, several subjects should be considered for inclusion in an MOC pro- cedure:

1) Define the need for and the purpose of an MOC system.

2) Establish accountability levels. 3) Specify criteria that will trigger formal change

requests. 4) Specify how personnel will submit change re-

quests and what form will be used. 5) Outline criteria for request reviews, as well as

responsibilities for those reviews. 6) Indicate that the MOC system encompasses:

•risks to those performing the work and other affected employees;

•possible property damage and business in- terruption;

•possible environmental damage; •product safety and quality; •procedures to accomplish the change; •results evaluafion.

7) Establish that minute-by-minute control must be maintained to achieve acceptable risk levels, and that risk assessments will be made as often as needed while work progresses; this will involve giving instruction on needed action if unanticipat- ed risks of concern are encountered.

8) Identify who wiU accept or decline a change request, including an MOC approval form.

9) Outline a method to determine the actions necessary because of the effect of changes (e.g., providing more employee training; revising stan- dard operating procedures and drawings; updafing emergency plans).

10) Indicate that work wul receive a final review before startup of operations, and idenfify the titles of those who wOl conduct the review.

Responsibility Levels In drafting an MOC system, responsibility lev-

els must be defined and must align with an entity's orgarüzational stmcture. This is a critical step in developing an MOC system. If even minor pro- cess changes are considered crifical with respect to employee injury and illness potential, possible environmental contaminafion, and product quality and safety, then the levels of responsibility are of- ten many. Some systems used as examples in this article clearly establish responsibility levels, while others do not.

Examples of responsibility levels, as outlined in an organizafion where inherent hazards require close control, are provided as reference points.

•Initiator: The initiator owns the change and is responsible for initiating the change request form. Based on complexities of the changes, these re- sponsibilities may be reassigned at any time. The inifiator fully describes and justifies changes; en- sures that all appropriate departments have as- sessed changes; manages execution of the change request; and ensures that the changes are imple- mented properly.

•Department supervisor: The department su- pervisor assigns qualified personnel to initiate change requests. The change control process is crifi- cal to employee safety, as is avoiding environmental contamination and ensuring product quality. This supervisor ensures that the change request is fea- sible and adequately presented for review.

•Document reviewers: Document reviewers as- sess and approve change request forms. These ac- fivities include reviewing the document for accuracy and adequacy with respect to proposed changes.

•Approvers: Department managers should se- lect preapprovers with expertise related to the na- ture of the proposed change. Based on knowledge and expertise, each reviewer wul evaluate and as- sess the effect of the proposed change on existing processes in his/her area of expertise. Reviewers also must review and approve the change request form and the implementation plan to evaluate the

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change and ensure that the steps for implementa- tion are appropriate. This is the final review before the proposed change is implemented.

•Postimplementation approvers: Department managers should select posfimplementafion approv- ers who should ensure that the change has been ap- propriately implemented as indicated when approval for the requested change was given. This process also ensures that only the changes shown on the change request form have been implemented.

The MOC Process: Activities to Consider An organization's hazard and risk complexifies

and the desire to establish an adequate yet not complex MOC system shotüd be considered when identifying activities that wül acfivate that system. Activity categories may include the foüowihg:

•Nonroufine and unusual work is to be per- formed.

•Work exposes workers to sources of high energy. •Maintenance operafions for which prejob plan-

ning and safety reviews would be beneficial because of inherent hazards.

•Substanfial equipment replacement work. •Introducfion of new or modified technology, in-

cluding changes to programmable logic controüers. •Modificafions are made in equipment, facüifies

or processes. •New or revised work pracfices or procedures are

infiroduced. •Design specificafions or standards are changed. •Different raw materials wiü be used. •Safety and health devices and equipment wiü be

modified. •The site's organizafional structure changes sig-

nificantly. •Changes in staffing levels that may affect opera-

fional risks. •Staffing changes require a review of skiü levels. •The site changes how it uses contractors.

MOC Request Form An MOC request form is needed, and its content

should align with an organization's structure and in-place management systems (e.g., capital request procedures, work orders, purchasing procedures). Creating a digital form aüows flexibility for descrip- five data and comments. The form should include:

•name of person initiafing the request; •date of request; •department or section or area; •equipment, facüity or processes affected; •brief descripfion of proposed change and what

wiü be accomplished; •potenfial performance and SH&E consider-

ations; •titles and names of personnel who wül review

the change; •effect on standard operating procedures, main-

tenance, training and simüar functions; •space for reviewers to document special condi-

tions or requirements; •approvals and authorizations; •routing indicators or provisions for copies to be

sent to personnel responsible for training and up- dating operafing procedures, drawings and similar documents.

Sample change request forms can be found in some of the 10 examples posted in PS Extra (www .asse.org/psextra).

Implementing the MOC Process Senior management and safety professionals

rnust appreciate the magnitude of the task of ini- tiating and implementing an MOC system, and should expect push-back. Common obstacles in- clude egos, territorial prerogafives, the current power structure and normal resistance to change; remember, those affected may have had little expe- rience with the administrative systems being pro- posed. Although MOC systems have been required in the chemical industries for many years, the liter- ature reports that their applicafion has experienced difficulties. According to CCPS (2008):

Even though the concept and benefits of managing change are not new, the matu- rafion of MOC programs within industries has been slow, and many companies sfiü struggle with implemenfing effective MOC systems. This is partly due to the significant levels of resources and management com- mitment that are required to implement and improve such systems. MOC may represent the biggest challenge to culture change that a company faces, (p. 10)

Developing an effective MOC system may require evolufion in a compan/s culture; it also demands significant commitment from Une management, departmental support or- ganizations, and employees, (p. 11)

Management commitment, evidenced by pro- viding adequate resources and the leadership re- quired to achieve the necessary culture change, must be emphasized. Stated or written manage- ment commitment that is not followed by provid- ing the necessary resources is not management commitment. Because of extensive procedural re- visions necessary when initiating an MOC system, culture change methods should be applied. Sub- jects to consider when implementing the system include the foüowing:

•Management commitment and leadership must be obtained and demonstrated. That means pro- viding personal direcfion and involvement in ini- tiating procedures; providing adequate resources; and making appropriate decisions with respect to safety when disagreement arises about the change review process.

•Keep procedures as simple as practicable. An applied, less-complicated system achieves better results than an unused complex system.

•Obtain widespread acceptance and commit- ment. Inform all affected employees before inifiat- ing the MOC system, solicit their input, and respect their perspectives and concerns.

•Recognize the need for and provide necessary training.

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•Field-test a system before implementing it. De- bugging will produce long-term returns.

•After refining the system through a field test, select a job or an activity that would benefit—both productivity/efficiency and safety—from an MOC system, and emphasize those benefits to buud fa- vorable interest. Tesfing the system in a select ac- tivity demonstrates its value, makes it credible and creates demand for additional applicafions.

•Monitor system progress and performance via periodic audits, and informally ask employees for their perspectives.

Managing Organizational Change In some examples posted, procedures require

those involved to assess the significance of organi- zafional changes. These provisions exist because or- ganizational and personnel changes can negafively affect an operational risk management system.

Of the considerable literature on the subject. Managing the Health and Safety Impacts of Orga- nizational Change (CSChE, 2004) is cited because it fits closely with the intent of some examples provided. Types of organizational and personnel changes that can negatively affect operations risk management are:

Figure 1

Risk Assessment Matrix Severity levels and values

Catastrophic (5)

Critical (4) Marginal (3) Negligible (2) Insignificant (1)

Occurrence probabilities and values Unlikely (1)

4 3 2 1

Seldom (2) 10

8 6 4 2

Occasional (3) 15

12 9 6 3

Likely (4) 20

16 12 8 4

Frequent (5) 25

20 15 10 5

Note. Numbers were intuitively derived. They are qualitative, not quantitative. They have meaning only in relation to each other.

Incident or Exposure Severity Descriptions Catastrophic: One or more fatalifies, total system loss and major business down time, environ-

mental release with lasting effect on others with respect to health, property damage or business interrupfion.

Critical: Disabling injury or illness, major property damage and business down time, envi- ronmental release with temporary impact on others with respect to health, property damage or business interruption.

Marginal: Medical treatment or restricted work, minor subsystem loss or property damage, environmental release triggering external reporting requirements.

Negligible: First-aid or minor medical treatment only, nonserious equipment or facuity dam- age, environmental release requiring routine cleanup without reporting.

Insignificant: Inconsequential with respect to injuries or illnesses, system loss or downtime, or environmental release.

Incident or Exposure Probability Descriptions Unlikely: Improbable, unrealistically perceivable. Seldom: Could occur but hardly ever. Occasional: Could occur intermittently. Likely: Probably will occur several fimes. Frequent: Likely to occur repeatedly.

Risk Levels: Combining the severity and occurrence probability values yields a risk score in the matrb<. The risks and the acfion levels are categorized below.

Risk Categories, Scoring & Action Levels Action level Remedial acfion discrefionary. Remedial acfion to be taken at appropriate fime. Remedial acfion to be given high priority. Immediate acfion necessary. Operafion not permissible except in

' an unusual circumstance or as a closely monitored and limited exception with approval of the person having authority to accept the risk.

Category Low risk Moderate risk Serious risk High risk

Risk score I t o 5 6 to 9 10 tol4 15 or greater

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The culture change necessary to imple-

ment a successful MOC system is

impossible without a training program that

helps supervisors and workers understand

the concepts to be applied.

•reorgamzmg or reengmeenng; •workforce downsizing; •attrition and workforce aging; •outsourcing of critical services; •changes affecting the compe-

tence or performance of contrac- tors that provide critical services (e.g., equipment. design, process control software, hazard and risk assessment);

•loss of skills, knowledge or attitudes as a result of the cited changes.

According to CSChE (2004), such changes are not as well-addressed

in applicable guidelines as changes in equipment, tools, work methods and processes.

More emphasis must be given to the effect of orga- nizational changes on operational risk management because incident reports on some serious injuries and fatalities indicate that staffing reductions were a significant contributing facfor to unacceptable risk situations such as inadequate maintenance; inad- equate competency; workers being stressed beyond their mental and physical capabilities (e.g., two persons doing the work for which three had been previously assigned; a person working alone in a high-hazard situation for which the standard oper- ating procedure calls for a work buddy).

Risk Assessments Some of the examples posted require risk as-

sessments at several stages of the change activity. The intent is to achieve and maintain acceptable risk levels throughout the work. Thus, risk assess- ments should be conducted as often as needed as changes occur—and particularly when unexpected situations arise. SH&E professionals who become skilled risk assessors can offer a significant value- added consultancy.

Risk assessment is the core of ANSI/ASSE Z590.3, Prevention Through Design: Guidelines for Ad- dressing Occupational Hazards and Risks in Design and Redesign Processes. The standard's content is applicable to MOC whether the contemplated change involves new designs or redesign of exist- ing operations. Of particular interest are sections on supplier relationships, safety design reviews, hazard analysis and risk assessment processes and tech- niques, and the hierarchy of controls.

Risk Assessment Matrixes Z590.3 recommends use of a risk assessment

matrix, and stresses that all involved agree on the definitions of ferms used in the matrix. An adden- dum in Z590.3 provides several sample matrixes. The example presented in Figure 1 (p. 39) was pre- ferred by operating employees involved in the risk assessment process. They indicated that first es- tablishing a mental relationship between numbers such as 6 and 12 helped them more readily under- stand the relation between terms such as moderate risk and serious risk.

The Significance of Training CCPS (2008) emphasizes the significance of

training in achieving a successful MOC system: Training for all personnel is critical. Many systems failed or encountered severe prob- lems because personnel did not under- stand why the system was necessary, how it worked and what their role was in the imple-

. mentation, (p. 58)

The culture change necessary to implement a successful MOC system is impossible without a training program that helps supervisors and work- ers understand the concepts to be applied. Where the MOC system applies to many risk categories (occupational, public, environmental, fire protec- tion and business interruption, product quality and safety), training must be extensive.

Oocumentation An operation must maintain a history of opera-

tional changes. All modifications must be recorded in drawings, prints and appropriate files; they be- come the historical records that would be reviewed when future changes are made.

Comments that "changes made were not re- corded in drawings, prints and records" are too common in reports on incidents with serious con- sequences. Examples of unrecorded changes in- clude the following:

•The system was rewired. •A blank was put in the line. •Control instruments were disconnected. •ReUef valves of lesser capacity had been installed. •Sewer Une sensors to detect hazardous waste

were removed.

On the MOC Examples As noted, the 10 MOC examples covered in the

following discussion are posted in the PS Extra sec- tion of the ASSE website (www.asse.org/psextra).

To demonstiate the substance and variety of ac- tual MOC systems, few changes were made in the examples. In some cases, terms used are not read- üy understandable. However, these terms are Ukely understood within the organization that developed the system, so they are presented as-is to empha- size that the terminology included in an MOC pro- cedure must reflect the language commonly used within an organization and must be understood by all involved in an MOC initiative.

These examples vary greatly in content and pur- pose. Some are one page; others take several pages to cover the complexity of procedures and exposures. Some procedures have introductory statements on policy and procedure, others do not. Nevertheless, these examples show that an MOC system need not meet a theoretical ideal to provide value. These examples are intended as references; none should be adopted as is. An MOC system should reflect an organization's particular needs and its culture.

Example 1: Producing Mechanical Components This prejob p l a n n i n g and safefy analysis system

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(Figure 2) is a one-page outline developed because of adverse occupational injury experience in work that was often unusual or one-of-a-kind, or that required extensive, complex maintenance.

It is relatively simple- in relation to other exam- ples posted, yet it was successfully applied for its ' purposes. In this case, safety professionals:

•prepared, the data necessary to convince man- agement and shop floor personnel to try the pro- posed system;

•reported that training was highly significant in achieving success;

•emphasized that work situations discussed in training were real to that organization;

•addressed productivity/efficiency and risk con- trol benefits in their proposal and during tiraining.

For whoever initiates an MOC system, the fol- lowing procedure will be of interest.

At. a location where the serious injury experi- ence was considered excessive for nonroutine work, safety professionals decided that some- thing had to be done about it. As they pre- pared a course of action and talked it up at all personnel levels, from top management down to the worker level, they encountered the usual negatives and push-back (e.g., it would be time consuming, workers would never buy into the program, supervisors would resist the change). The safety professionals considered the negatives as normal expressions of resis- tance to change.

Their program consisted of, in effect, in-

Figure 2

MOC Example 1 Alpha Corporation

Pre-Job Planning and Safety Analysis Outline

1) Review the work to be done. Consider both productivity and safety: a) Break the job down into manageable tasks. b) How is each task to be done? c) In what order are tasks to be done? d) What equipment or materials are needed? e) Are any particular skills required?

Clearly assign responsibilities. Who is to perform the pre-use of equipment tests? Will the work require: a hot work permit; a confmed entry permit, lockout/tagout (of what equipment or machinery), other? Will it be necessary to barricade for clear work zones? Will aerial lifts be required? What personal protective equipment will be needed? Will fall protection be required? What are the hazards in each task? Consider: •Access 'Explosion •Chemicals 'Fall Hazards •Conveyors ' •Fire • Dropping tools •Forklitl trucks •Dusts •Hot objects •Electricity •Machine guarding • Elevated loads •Moving equipment

10) Of the hazards identified, do any present severe risk of injury? 11) Develop hazard control measures, applying the Safety Decision Hierarchy.

• Eliminate hazards and risks through system and work methods design and redesign • Reduce risks by substituting less hazardous methods or materials • Incorporate safety devices (fixed guards, interlocks) • Provide waming systems •Apply administrative controls (work methods, training, etc.) •Provide personal protective equipment

12) Is any special contingency planning necessary (people, procedures)? 13) What communication devices will be needed (two-way, hand signals)? 14) Review and test the communication system to notify the emergency team (phone number, responsibilities). 15) What are the workers to do if the work doesn't go as planned? 16) Considering all of the foregoing, are the risks acceptable? If not, what action should be taken?

Noise Pressure• Sharp objects Steam Stored energy Twisting, bending Vibration

•Weather • Weight of objects •Welding •Work at depths •Work at heights • Worker position •Worker posture

Upon Job Completion 17) Account for all personnel 18) Replace guards 19) Remove safety locks 20) Restore energy as appropriate 21) Remove barriers/devices to secure area 22) Account for tools

23) Tum in permits 24) Clean the area 25) Communicate to others affected that the job is done 26) Document all modifications to prints and appropriate

files

To view and down- load each ot the

10 MOC examples cited, visit www

.asse.org/psextra.

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doctrinating management and the workforce in the benefits to be obtained by doing pre- reviews of jobs so that the work could be done effecfively and efficiently while at the same time controlling the risks.

Eventually, management and the line workers agreed that classroom training ses- sions could be held. Later, the safety pro- fessionals said that the classroom training sessions and follow-up training were vital to their success.

At the beginning of each of those sessions, a management representafive introduced the subject of prejob planning and safety analy- sis and discussed the reasons why the new procedure was being adopted. Stafistics on accident experience prepared by safety pro- fessionals were a part of that introduction. Then, safety professionals led a discussion of the outline shown in MOC Example 1. It set forth the fundamentals of the prejob review system being proposed. After discussion of those procedures, attendees were divided into groups to plan real-world scheduled mainte- nance jobs that were described in scenarios that had been previously prepared.

At this locafion, supervisors took to the pre- job planning and safety analysis system when they recognized that the system made their jobs easier, improved productivity/efficiency, and reduced the risks. And they took owner- ship of the system. As one of the safety pro- fessionals said, "Our supervisors and workers have become real believers in the system." And a culture change had been achieved.

Note the requirements under the caption "Upon Job Completion." The detail of the requirements reflects parficular incidents with adverse results that occurred over several years. Every MOC sys- tem should include similar procedures to be fol- lowed before work can be considered completed.

Exampie 2: Speciaity Construction Contractor This two-page field work review and hazard

analysis system was provided by a safety profes- sional employed by a specialty construction con- tractor that has several crews active in various places at the same time. Note that the names of employees on a job must be documented as hav- ing been briefed on the work to be performed. The checklist included in this example pertains to oc- cupational, public and environmental risks.

When asked what drove development of the change procedure, the safety professional said the firm had learned from costly experience. Accord- ing to this professional, the procedures required by the change system are now embedded in the com- pany's operafions and are believed to have resulted in greater efficiency. In addition, fewer costly inci- dents have occurred.

This example has a direct relafion to the purposes of construcfion/demolition standard ANSI/ASSE 10.1, Pre-Project and Pre-Task Safety and Health

Planning. This standard is an excellent resource for contractors and companiess that establish require- ments for on-site contractors. Note the distinctions: preproject planning and pretask planning.

Exampie 3: Serious Injury Experience This pretask analysis form emphasizes obtain-

ing required permits and ensuring that supervisors brief employees on the order of activities and about the risks to be encountered. Employees must sign the form to confirm this briefing; it is the only ex- ample that requires employee signatures.

Exampie 4: !\/lanagement Poiicy & Procedure This basic guidance paper is condensed to three

pages. It is a composite of several MOC policies and procedures issued by organizations in which operations were not highly complex. Reference is made to an MOC champion. Someone must be re- sponsible for the change and manage it through to an appropriate conclusion.

Example 5: SpecificaUy Defined Prescreening Questionnaire

In three pages, this system commences with an interesting prescreening questionnaire. If the answer to all questions is "no," the formal MOC checklist and approval form need not be complet- ed. With respect to MOC systems, it's often asked, "To what work does the system apply?" This orga- nization developed a way to answer that quesfion for its operafions.

Exampie 6: Higii-Risk Multiproduct Manufacturing

This MOC policy and procedure reflect the or- ganization's high-hazard levels. Captions in this four-page example are: safety; ergonomics; occu- pational health; radiation control; security/prop- erty loss prevention; clean air regulafions; spul prevention and community planning; clean water regulations; solid and hazard waste regulations; environmental, safety and health management systems; and an action item tracking instrument.

According to the procedure paper announcing the system:

If a significant change occurs with respect to key safety and health or environmental per- sonnel, the matter wul be reviewed by the S&H manager and the environmental man- ager and a joint report including a risk as- sessment and their recommendations wiU be submitted to location management.

Exampie 7: A Food Company This four-page policy includes product safety

and quality as subjects to be considered. The safety director reports that discipline in the applicafion of this MOC system is rigid, which reflects manage- ment's determination to avoid damaging incidents and product variations. Provisions for prestart-up and postmodification are extensive. Risks are as- sessed after changes are made and before start-up.

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Example 8: Conglomerate Iota Corp. has a five-page MOC procedure out-

lined in four secfions. Secfion I requires completion of a change request and tracking system require- ments form in which the change is described, a tracking number is assigned and approval levels are established. Approval levels are numerable, in- cluding headquarters in some instances.

Section n outlines a change review and approval procedure that is extensive with respect to occupa- tional safety, health and environmental concerns. Section in is a preimplementafion action summary form that lists subjects for which acfions are nec- essary before change can begin, and it identifies those responsible for those actions. Secfion IV lists 11 points in a postcomplefion form.

Example 9: Extensive System fora Particular Operation

This seven-page example is valuable because of its structure and content. It is somewhat different compared to the other examples. It:

•handles requirements for technical changes and organizafional changes separately and extensively;

•stresses organizafional changes for which risk assessments are required;

•outlines in detail technical changes to which the standard applies;

•lists risk assessment as a separate item that per- tains to all operations;

•includes a lengthy discussion of general con- siderafions, and outlines and thoroughly discusses requirements for a six-point MOC standard: man- agement process; capability; change idenfificafion; risk management; change plan; and documentation.

This is a concept and procedural paper. It does not include the forms used to implement the vari- ous procedures.

Example 10: International Multioperational Entity Application of this system, titled Management of

Change Policy for Safety and Environmental Risks, extends the acfivifies of SH&E professionals be- yond that of any other example. It covers 10 pages, although the bulletin issued by the safety enfity within the organization is much longer.

Only two of five exhibits were made available because of proprietary reasons. Unique aspects in- clude the following:

•Due diligence is included in a Hst of definifions. SH&E professionals are to assess acquisitions and similar transacfions.

•Global franchise management board members are listed under responsibilifies. They are to ensure compliance with the standard.

•A preliminary SH&E assessment questionnaire shall be initiated during the project planning stage.

•A secfion fitled Evaluafing Change (Risk Assess- ment Guidelines) includes these subjects, which may not be included in other examples, at least not as extensively:

a) new process product and development; b) capital/noncapital project; c) external mantifacturing;

d) business acquisifions; e) significant downsizing/hiring. •Conducting risk analyses is a major section. This example is noteworthy because of its

breadth. Interestingly, the system was issued by the safety and industrial hygiene unit, which im- plies management support for superior operafional risk management.

Conclusion This arficle has provided a primer that SH&E

professionals can use to craft an organizafion-spe- cific MOC/prejob planning system. Safety profes- sionals should consider whether their employers could benefit from having such a system in place. Having a system that prestudies changes because of their inherent hazards and risks and their poten- tial effect on safety, productivity and environmen- tal controls is good risk management. PS

References

American Society for Quality (ASQ). (2000). Qual- ity management systems: Requirements (ANSI/ASQ Q9001-2000). Milwaukee, WI: Author.

ANSI/ASSE. (2011). Construction and demolition operations: Preproject and pretask safety and health planning (ANSI/ASSE AlO.1-2011). Des Plaines, IL: Author.

ANSI/ASSE. (2011). Prevention through design: Guidelines for addressing occupational hazards and risks in design and redesign processes (ANSI/ASSE Z590.3-2011). Des Plaines, IL: Author.

Canadian Society of Chemical Engineering (CSChE). (2004). Managing the health and safety impacts of organizational changes. Ottawa, Canada: Author. Retrieved from www.cheminst.ca/index .php?ci_id=3210&la_id=l.

Center for Chemical Process Safety (CCPS). (2008). Guidelines for management of change for process safety. Hoboken, NJ: American Institute of Chemical Engineers, Author.

Chemical Manufacturers Association. (1983). A manager's guide to implementing and improving manage- ment of change systems. Washington, DC: Author.

NSC. (2000). Aviation ground operations safety hand- book (5th ed.). Itasca, IL: Author.

OSHA. Safety and health management system eTool: Worksite analysis. Washington, DC: U.S. Department of Labor, Author. Retrieved from www.osha.gov/SLTC/ etools/safetyhealth/comp2.html.

OSHA. (1992). Process safety management of highly hazardous chemicals (29 CFR 1910.119). Washington, DC: U.S. Departrnent of Labor, Author.

OSHA. (1994). Process safety management guideline for compliance (OSHA Bulletin 3133). Washington, DC: U.S. Department of Labor, Author. Retrieved from www.osha.gov/Publications/osha3133.pdf.

Stephens, R.A. (2004). System safety for the 21st century. Hoboken, NJ: John Wuey & Sons.

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