This article is going to cover everything you need to know about management of change, the processes included, and how to build a reliable system. Regardless of your current understanding of management of change this article will have something for you!
What is management of change?
The term “management of change” refers to the process of making changes to existing facility design, operations, organization, or activities in a way that will not introduce new hazards or increase the risk of existing hazards. The goal is to ensure employees, the public, or the environment will not be negatively affected by the proposed adjustments. This involves a review and authorization process for evaluating proposed changes before implementing them. It also includes steps to notify potentially affected personnel of the changes.
Why do I need to care about management of change?
If management of change processes are not followed employees can be seriously injured or killed, or disastrous events can take place in some circumstances. In less extreme cases management of change processes are simply used to ensure that changes are documented and well understood before they are made.
In the case of PSM requirements there are actually some pretty hefty fines associated with not following and documenting a management of change process. These requirements are laid out by CFR 1910.119 and can be found here.
What are the OSHA management of change requirements?
OSHA actually only requires management of change tracking for companies that fall under PSM regulations. If your company does not, then you don’t need to worry about them for regulatory reasons. However, they aren’t a bad practice as they can prevent changes than may negatively impact employees or production. The management of change (MOC) section of the PSM standard requires employers to develop and implement written procedures to record and manage all changes associated with chemicals, technology, equipment, procedures, or facilities covered by PSM. They must include descriptions of the technical reason for the change, the impact on health and safety, any modifications made to procedures, the time period necessary for the change, and the authorizations required to make the change. As stated earlier, any employee who may be affected by the change must also be informed and trained on the change. Even temporary changes must be documented as well as the time limit and reason for the change. If you are ever audited by OSHA you will need to produce all of the documentation, approvals, and training records for your MOC’s.
What tools exist to make management of change easier?
Many companies rely on paper approval methods or something like document sharing programs sent over emails. Although this does work it is not easy to track and may actually make managing a program more difficult. Ideally, MOC should give you and transparent, easily accessible change request system. This system should ensure that no changes can be made without all risks and controls identified, or without proper authorization. Generally, it makes sense to use a program specifically designed to establish, track, and manage your MOC’s. MOC software like this is designed to make management of change easier and save your company time and money. It also ensures you don’t have to worry about losing track of paperwork or approvals.
Multi-facility cloud-based solutions offer the best value to companies with change management needs as they enable easy access to the correct personnel and offer record keeping in case of review or audit. They ensure the MOC’s are available anywhere at any time and give companies mobile capabilities so they aren’t restricted to their desk.
How to create an MOC.
Management of change can differ from company to company, but an effective one makes all the difference. Most organizations have written procedures detailing how management of change will be implemented. These procedures apply to work that is considered not to be replacement in kind or RIK. An MOC review form is used to document the results of the review process and any documents providing additional information about the change are attached to the form. (A more comprehensive management of change process can be found here.) Here are the steps that should be taken-
- Create a detailed change request
- Make the request easy to access
- Notify approvers for pre-approval
- Once pre-approved, notify reviewers
- Once reviewed, follow your PSR checklist (if required)
- Notify approvers for final approval
- If at any step it is not approved, make the necessary changes and revert to step 3
After a change is approved, be sure that all affected employees are trained on and understand the change and how it affects their work before the change is made. Perform training regularly to prevent incidents and injuries surrounding your process.
Is management of change software right for you?
Obviously, this is something your company must decide for itself, but here is what you should consider.
If you like knowing changes you make in your facility are not going to kill employees or cause catastrophic fallout, if you like avoiding OSHA fines, if you want your job to be easier, or if you like saving time and money, being more organized, and having trackable and professional records- MOC software is exactly what you need.
Schedule a demo of the BasicSafe MOC tool today and try it out yourself by clicking the button below or learn more here.