For businesses in the chemical industry and other high-risk industries, health and safety risks are an inherent part of the job. Managing these risks is often a matter of life and death, for people and for the future of the business itself.
On June 21, 2019, the Philadelphia Energy Solutions complex exploded, releasing 3,271 pounds of hydrofluoric acid into the atmosphere, sending pieces of shrapnel flying through the air and injuring five workers. The refinery promptly closed and filed for bankruptcy. The accident, which began with a pipe failure, was similar to a 2012 Chevron refinery incident and could have been prevented if PES followed inspection recommendations, according to the Philadelphia Inquirer.
The PES incident stemmed from a failure to monitor operations and equipment and make the organizational changes necessary to ensure safety. It serves as an example of poor process safety management and management of change. In fact, most large scale incidents (80%) can be traced back to a failure related to management of change, according to Chemical Engineering Transactions.
What is Management of Change?
Management of Change (MOC) is part of process safety management and fits into an organization’s broader environmental, health and safety management framework. It ensures risk is carefully and proactively addressed whenever a change is made to processes, systems, organizational structure or job roles.
Management of Change is a systematic process to control environmental, health and safety risks during organizational changes.
Businesses may use management of change processes after a merger or acquisition, when staffing levels change, when new materials are introduced or when equipment is updated. The process may be used for changes that are permanent, temporary or in case of emergency. Facilities that use hazardous chemicals and are subject to the U.S. Occupational Safety and Health Administration’s process safety management regulations are also subject to OSHA requirements for management of change.
How to Conduct Management of Change
The concept for management of change dates back to the 1940s when social psychologist Kurt Lewin first developed a model for organizational changes. Lewin’s model included three stages: First “unfreezing” current processes; then “changing” to new, safer procedures; and finally, “freezing” in those changes as part of normal operations. Today, the management of change process has been expanded and refined to include several more steps:
- Initiation — Identifying what needs to be changed
- Pre-Approval — Gaining consent to evaluate potential changes
- Evaluation — Engaging stakeholders to consider the impact of change
- Approval — Permission to begin making the change
- Implementation — Making the change
- Pre-Startup Safety Review — Ensuring new processes are safe
- Approval to Startup — Getting authorization to resume normal operations with the change in place
- Post-Startup — Reviewing processes to ensure they are working as planned
- Closure — Signing off on the process and recording it
Due to the complexity of the process, and to ensure change occurs in a standardized method across a business, many companies choose to use management of change software to help streamline this process.
Management of Change is an essential part of environmental, health and safety management strategies. The process ensures companies stay compliant and promote safety while positioning themselves for continuous improvement and innovation.