The day to day operations at manufacturing plants may vary based on industry and facility, but the need to manage safety is consistent. For manufacturing businesses, change is inevitable – and can be a positive source of growth and advancement. However, change is only beneficial if you manage it properly, and that means being prepared through planning and training. As a result, safety measures meant to maintain safety despite changes must be established. OSHA works with industries to establish a set of procedures and practices to ensure safety for facilities and workers. Management of Change (MOC) is a set of procedures aimed at preventing unintended risks and complications associated with a change in an organization. OSHA clearly defines management of change:
OSHA 1910.119(l) Management of Change
The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process.
What is the Purpose of Management of Change (MOC) Regulations?
Perhaps you are wondering, what are the real-world implications and impacts of Management of change? Management of change procedures are closely tied with process safety management (PSM). PSM is a systematic way for industries to manage hazards associated with processes to reduce the frequency and severity of incidents. The incident that shed light on the need for PSM was the Phillips disaster of 1989. This incident took place during a routine maintenance procedure where valves were not properly identified. This accident resulted in an explosion that killed 23 employees and injured 314. The reason cited for the incident was a lack of PSM measures.
OSHA’s Process Safety Management (PSM) standard MOC is now mandatory when changes are made that could affect the safety of a facility. Changes include alterations in process chemicals, equipment, technology, and procedures. Temporary changes can also cover repairs, staffing, and other operating conditions. As a result, an effective MOC program must address all changes possible that may occur on-site and that may pose potential safety risks—permanent and temporary.
Creating Sound MOC Procedures
MOC procedures are intended to mitigate all risks that result from change. The known risks of a facility, along with unforeseeable risks can be organized and ranked according to severity. These risks can oftentimes require accompanying training procedures to properly manage high risk scenarios.
OSHA requires the following procedures for MOC:
- The technical basis for the proposed change
- Impact of change on safety and health
- Modifications to operating procedures
- Necessary time period for the change
- Authorization requirements for the proposed change.
Once workers are properly trained, a special team known as a change management team is typically created to handle the changes. This team efficiently manages all process changes with communications with stakeholders to communicate project tasks and status efficiently. The figure above shows a model for MOC that provides an OSHA compliant, seamless plan of action.
Process Safety Management
Process Safety Management (PSM) encompasses a detailed set of requirements and procedures employers must follow to proactively address hazards associated with processes and equipment. Essentially, a PSM program is focused on keeping a specific process running safely and smoothly by preventing injuries and improper activities through training and regular monitoring. While maintaining a PSM program for each process can sound like a lot of work, it’s an impressively effective method for keeping overall costs low by reducing downtime due to incidents or improper equipment usage.
For example, facilities and businesses that use large amounts of hazardous chemicals require PSM programs to cover operating procedures and mechanical procedures for compliant inspections. This is to ensure your safety team is taking the right actions to protect workers from chemical exposures and that the correct personal protective equipment (PPE) is always being used.
OSHA requires that facilities must:
- Keep up-to-date process safety information
- Conduct an incident investigation of any incidents that occur
- Certify or evaluate the PSM program every three years, or earlier as required
- Establish and implement procedures to maintain changes in the process
- Provide and document employee training
OSHA issues serious citations when death or serious physical harm is likely to result from hazards about which the employer knew or should have known. Let’s take a look at a case study about these citations in the next section to learn more about the benefits of having a good PSM program.
Process Safety Management Case Study: MECHANICAL INTEGRITY
Of OSHA PSM Citations over the past few years, mechanical integrity topped the list. If we dig a little deeper, we can see that the Department of Labor cites Inspections and testing as well as written procedures as the top reasons for mechanical integrity violations. For instance, in 2012 a Chevron Refinery in Richmond, California experienced a fire that resulted from inadequate mechanical integrity issues injuring six employees due to a ruptured pipe and was cited for mechanical integrity violations because inspections where not done properly to observe and repair the pipe before the incident.
Out of all the the specific OSHA subsections for Mechanical Integrity “inspections and testing” require inspections and tests on process equipment, sound inspection and testing procedures, consistent inspection and testing frequency, and proper documentation to be consistent with OSHA guidelines.
PSM standards also require the frequency of inspections and tests of process equipment to be consistent with applicable manufacturers' recommendations and good engineering practices, and inspections must be conducted more frequently if determined to be necessary. Mechanical Integrity relies on a set of recurring tasks along with meticulous recordkeeping of inspection tasks, and facilities and workers are likely to be in danger without them.
The Ultimate Solution for MOC—Automation
Management of Change and Process Safety Management are fundamental elements of keeping your existing processes running smoothly (PSM) and for ensuring they continue to operate efficiently when a change is required (MOC). However, both require constant upkeep and a lot of legwork for your Health & Safety department. It can be a huge investment in time and resources, especially if you have several processes to manage.
One of the best ways to invest in PSM or MOC is to automate as many of the microprocesses that you can. For example, having an automated compliance calendar that can automatically delegate inspection tasks to H&S staff on the dates they are required can save a manager many hours in reviewing each PSM program and manually scheduling in inspections. Businesses should map out the important procedures alongside compliance reporting and procedures then use automation to support any procedures that are in line with strategic goals and compliance. That’s why investments into MOC and PSM programs yield a strong return: in addition to fine avoidance, you can also reduce the costs associated with the everyday tasks required by a robust MOC program.
Software that automates the MOC and PSM procedures establishes a clear path for employees to demonstrate compliance to OSHA regulators. When facilities use Management of Change software, they get streamlined data management, automated communication between stakeholders, progress tracking, and simplified task delegation all through one web-based platform. Software tools for MOC aid facilities and workers to make improved innovations like having clear guidelines for processes like mechanical integrity. Compliance reminders requiring supporting written procedures, daily inspections, and training are enhanced ways software can bolster your MOC system. We recommend establishing error proof processes to protect your facility and workers in the face of any changes. Using a combination of MOC and PSM software your facility can exemplify the best practices of worker safety by saving lives and improving processes—making every facility safer and more efficient.
September 19, 2019