Management of Change

Management of change (MOC) is the process used to review all proposed changes to materials, technology, equipment, procedures, personnel, and facility operations before they are implemented to determine their effects on safety vulnerabilities. If the review determines that a proposed change would impact safety vulnerabilities, then 1) the applicable safety information should be updated and 2) all employees whose job tasks will be affected by the change should be informed and retrained prior to resumption of work.

All proposed modifications to equipment, procedures, materials, or process conditions should be subjected to the review process. For example, standard operating procedures generally describe the acceptable operating ranges of process parameters (e.g., flow rates, concentrations of critical components in mixtures, pH ranges, temperature limits, pressure limits, and valve configurations). A knowledgeable person should evaluate any proposed changes in these process parameters to ensure safe operation. If the proposed change is determined to be safe, operators should be informed about the parameter change and trained to respond with the appropriate actions if the parameter should fall outside of its acceptable range (e.g., notify supervisors, change process settings, shut down process) in order to maintain a safe working environment.

Management of change is usually interpreted as relating to permanent changes to equipment, procedures, processes, or personnel, but temporary changes have contributed to a number of catastrophic events over the years. Temporary changes (e.g., abnormal situations, deviations from standard operating conditions, untrained personnel filling in during an expected absence) should be managed as if they were permanent changes. Written documentation of normal process parameters, use of standard operating procedures, management sign-offs, and clear communications are necessary.

Although OSHA Process Safety Management Standards and EPA Risk Management Plan mandates require that covered facilities manage change systematically, experience also suggests that MOC principles apply at the laboratory scale for hazardous work being performed. Consider the safety implications of scaling-up an experiment or even making changes at the smallest scales of any reaction chemistry. Perhaps a new research student is now working in the laboratory. Systematic approaches to managing change in the laboratory are important to ensuring a safe work environment.

A change control form or checklist is useful to facilitate change management procedures. The form should include a description of the proposed change and why it is being made, safety, health, and environmental considerations, and any resulting changes to existing procedures, documents, drawings, safety plans, or training requirements. All required approvals should be obtained before any change is implemented. If the impact of the change is minor and clearly understood, a checklist reviewed by an authorized person and communicated to affected employees could be sufficient. But for a complex or significant change, a hazard evaluation procedure with approvals by operations, maintenance, and safety departments is appropriate. Planned changes for facility design, equipment, materials, operating procedures, etc., should be noted so that the revisions can be made permanent when facility drawings and/or procedure manuals are updated. Documents describing changes should be kept in an accessible location to ensure their availability to operators, first responders, and others who may need to know.