Management of Change

MOC is a requirement of certain industrial companies in the United States, it is also reflected in various requirements for ISO 9001. Some of these requirements include change control, operational management, and change planning, among others. However, MOC can be applied in other industries as well, as it facilitates the safe and seamless adoption of new processes by organizations.

The ultimate goal of MOC is to protect workers from potential harm that may arise during the implementation of changes. This is why agencies such as EPA, OSHA, and COMAH are all involved in MOC procedures. Implementing changes in the workplace without conducting a MOC can compromise workplace safety and jeopardize compliance with legal requirements (OSHA 1910.119) and industry standards (ISO 45001) on occupational health and safety.

Change: A Risky Endeavor

When organizations undergo major changes, workers are put at higher risk. Studies show that the risk of work-related injuries and hazards is much higher during periods of change, which is why MOC is crucial in protecting employees from avoidable accidents and incidents.

All change can result in unforeseen consequences. Even changes that are put in place temporarily add an element of risk to workplace operations. These risks are amplified further in companies that deal with hazardous chemicals, materials, and heavy machinery.

This is why managers need to put a lot of thought into any change before introducing it to an organization. Before introducing any sort of change to a process, all the risks need to be considered, and accounted for, and actions need to be taken to alleviate these risks, which is the essence of MOC.

Changes That Trigger an MOC

Organizational changes are implemented occasionally for reasons such as production efficiency and streamlining of processes. Changes, however, can pose risks to employees if they are implemented without conducting an MOC. Here are some examples of changes in the workplace that can trigger the need to perform a MOC:

Physical

These can be engineering or physical changes that include new or modified equipment, a new or renovated facility, and process chemicals that can pose new safety risks that need to be evaluated.

Operations

Changes to how work is done or employees are managed will need to be assessed for possible new risks. New Standard Operating Procedures (SOP), changes to maintenance safety checks, new technology, or changes brought by reorganization need to be considered for new risks.

Personnel

Changes to staffing, training for employees, and other changes that will impact the safe execution of tasks should be evaluated before implementation.

How MOC Alleviates the Risk of Change

When companies implement MOC, it means that they thought the change through before introducing it and applying it within the company. When creating a MOC strategy, teams need to dive deep into any potential consequences of the change they want to introduce, assess the risks involved, and make sure that actions are in place to alleviate the risk and make the implementation for all employees.

MOC forces leaders and team managers to take a step back and look at the bigger picture before implementing the change. Even if the change has a lot of potential benefits, they need to be weighed against the risks to ensure that the risks are worth the rewards.

A lack of planning when introducing a change in an organization can have a lot of impacts. For example, it can impact personnel, their families, and even the environment. However, a MOC assesses all of these risks and puts measures into place to make sure these risks don’t reach a point where the employees and environment are in danger.

Which Agencies Are Involved With MOC?

MOC can work with any industry. However, it’s required for industries and companies that deal with specific hazardous chemicals. For these companies, here are some of the agencies involved in keeping them in check;

EPA

The Environmental Protection Agency (EPA) implements many change management guidelines for companies that deal with chemical hazards. This is to ensure that no chemical-related incidents that result from newly implemented changes cause harm to the environment and communities surrounding the organization.

The EPA has placed many guidelines and requirements that these companies need to comply with when implementing a change.

OSHA

The Occupational Health and Safety Administration (OSHA) is responsible for ensuring that all companies in the United States comply with Safety Guidelines the organization sets. OSHA has a specific regulation known as Process Safety Management which is a systemic approach to MOC.

With that said, PSM only applies to specific companies and industries, particularly those that deal with highly reactive or toxic chemicals in their processes.

COMAH

Control of Major Accident Hazards (COMAH) is the UK equivalent of EPA and OSHA regulatory bodies. The office also has certain guidelines for industries to follow in regard to chemical and fire hazards, similar to OSHA and EPA.

How to Implement MOC in an Organization

While MOC is required for specific industries, it can improve safety in just about any organization, especially when major changes abound. Implementing a MOC can get tricky, but it is much easier when organizations take a systematic and proper approach to their MOC.

The process of implementing a MOC varies for every company. However, teams need to ensure that they cover all the following steps when creating a MOC system.

• Look at the bigger picture: organizations need to assess the change they wish to implement and consider all possible outcomes and consequences. Recognizing all the changes and potential outcomes is crucial in figuring out the appropriate safety measures to take.

• Understand that hazards aren’t permanent: certain measures and actions can do wonders at reducing risks and hazards that arise during a change in the workplace. Not all risks can be avoided, and that’s a fact, but companies can still take measures to ensure that the risk is as low as possible.

• Check if the change is feasible: it’s important to understand whether or not a company can accomplish the change without running into major issues. And if any issues arise from the change, they need to be accounted for.

• Conduct a PSSR: a pre-safety startup review (PSSR) is crucial before implementing any change. This is to ensure that also safety measures are in place before implementing a change.

• Implement the change only if safe: if there are high risks involved with the change, it’s not worth doing. So, make sure that you only proceed with changes after determining all the risks and deciding that they are manageable.

• Make the necessary changes: there’s a high chance that teams will meet some bumps in the road when implementing a change. So, it’s important to take notes from people on the ground and make adjustments accordingly.

Implementing a MOC system is complicated and can take a lot of time. However, there are certain measures that companies can take to make the implementation easier. That way, they won’t have to struggle to ensure the safety of workers during change.

Tips on How to Successfully Implement Management of Change

Since the primary reason for doing an MOC is to assess and confirm if a change in the business process will be welcomed and beneficial, the process itself should also be done carefully. All important details should be laid out and addressed so that no critical aspects are missed and that businesses come up with a credible resolution for the initiative. Here are the top tips on how to effectively implement an MOC procedure:

Assess the proposed change from different perspectives

Collect as much information as you can, be as inclusive as possible, and don’t just focus on one or two voices in the organization. Changes can appear differently based on personal biases and individual goals, so looking at the effects of changes from various perspectives can help devise a fair and reasonable outcome.

Prioritize your people

Gather feedback from employees, especially those that will be directly affected by the change. If, by the end of doing the MOC, you’ve determined that there could be a significant negative impact on the organization or the people, specifically safety issues, don’t push through with the proposed change.

Don’t compromise safety, no matter how big the surface rewards may be. After all, you can only really say an endeavor is successful if there’s no lasting detrimental effect on the people and the business.

Utilize ready-to-use checklists or templates

A lot of information is required when doing an MOC so it’s best to leverage tools such as checklists that can hold all these data in one safe place. Deploying digital checklists, particularly, provide authorized stakeholders with a shared overview of the value and status of a proposed change.

Using a management of change template also allows for easy monitoring and efficient tracking for future reference.