Controlling Risk by Managing Change Jessica Blaydes & Gary Fobare Honeywell Aerospace 2013 Region IX Workshop.

Controlling Risk by Managing Change

Jessica Blaydes & Gary FobareHoneywell Aerospace

2013 Region IX Workshop

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Goals for this Workshop

• Discuss-What is Management of Change?

-Why focus on Management of Change?

-What types of changes should be included in the process?

-Keys to Success

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What is Management of Change?

•The legal definition…-OSHA 1910.119(l)(1)“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.”

-Only applies to process safety, so limited legal applicability to “covered processes”

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What is Management of Change?

•A non-regulatory definition…-Sam McNair, Life Cycle Engineering

“A process for preventing or mitigating business losses – including degradation of safety, health or environment – as the result of changes made to how you construct, operate, manage, or repair your facility or your processes.”

(Source: http://www.reliableplant.com/Read/25905/misperceptions-management-change)

-Every business, regardless of legal requirements, needs to control potential losses

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What is Management of Change?

•Honeywell’s definition…-Honeywell Aerospace HSE Management System Standard:

“A documented process to review modified or new materials, equipment, facilities, processes and new/changed requirements to assure HSE risks are proactively identified, evaluated and controlled.”

Goal: Ensure that risks associated with changes…are assessed to safeguard people, the environment, property and the public.

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Why focus on Management of Change?

• Some sources indicate that a high percentage of serious accidents in industry are related to uncontrolled change

• MOC is like an insurance policy that pays off by preventing accidents

1. To identify and control hazards

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Effects on product quality

The Impacts of Change Are Not Always Obvious

New shelf life requirements

Operator training needs

Different storage

requirements

Change in chemical usage

Increased hazardous waste

Increased PPE needs

Example of Change: Change in Chemical Usage

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Why focus on Management of Change?

• Regulatory Requirements- Process Safety Management

• Internal Requirements- Management Systems

• External Requirements- Customer Requirements

2. To maintain compliance

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Why focus on Management of Change?

• Employees understand why change is happening• Employees engage in the solution and the change • Resistance is identified and dealt with early in the process• Leaders demonstrate their commitment to the change• The organization begins to build a history of successful change,

creating a better 'backdrop' for the next change initiative• Changes are less painful to the organization and to the employees

3. To keep people informed

MYTH:  A great solution + Effective project management =

Project success

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What Types of Changes Need to be Managed?

• It is up to each business to assess risk and define its tolerance for uncontrolled change

• Site leadership must define change in terms consistent with the business interests and any regulatory requirements

• Clear definition is critical to prevent:- Crippling the program’s effectiveness

- “Analysis Paralysis”

- Loopholes for those who wish to bypass the process

• What risks do you wish to control and what sorts of changes, if not controlled, increase those risks?

“The most difficult part of management of change is recognizing change.”

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What Types of Changes Need to be Managed?

Keep it Simple!

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What Types of Changes Need to be Managed?

Clear definitions help get the point across

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Temporary Change

• Temporary Changes should not be exempted from the process!- Routine temporary changes

Example: Bypassing interlocks for periodic maintenance Treat the situation as a permanent change, incorporating it into approved

procedures with appropriate safeguards

• Managing Change - Must have an acceptable duration of time (expiration date)

- The expiration date and time for the temporary change should be documented on the MOC form

- Additional safeguards may be required during a temporary change to manage potential risks (to be listed on the MOC form)

Of all of the uncontrolled changes that occur, “temporary” changes are the most frequent

cause of accidents and incidents.

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Emergency Change

“We don’t have time to do a MOC, this is an emergency!”

• Emergency Changes (some examples)- Sudden exit of senior leader from the organization

- Moves required due to emergency conditions (fire, flood, outage, etc.)

- Out of compliance condition; permit/legal violation

- Immediate need for policy change to comply with legal requirements or protect people or property

- Fast turnaround on equipment changes due to catastrophic event

During an emergency is precisely when the discipline imposed by the MOC process is most necessary.

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Keys to Success

• Solid understanding of what constitutes a change- Training, practice and coaching is required to ensure

understanding of what falls under the process

• Don’t get hung up on the past- MOC is about managing future risk and loss

- We all inherit messes, but the one thing we can do is implement MOC right now

• Streamlined approval process- Ensure required approvals are appropriate to the change and the

potential risk associated with it

- Be flexible enough so that approvals can be tailored to the situation at hand

- Minimize the number of approvers, and make them the right ones

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The MOC Form - Example

The form should be easy to use but still capture the required approvals for each potential change impacting the site

What is the current state?

What is the change?

How will you communicate the change? What needs to be

done to implement the change?

HSE, STE & Quality Review

MOC Council Sign-off

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Points to Remember

• Learning to recognize when MOCs are required will be the key to success

• Submit MOCs in advance of the change so there is time to address implementation requirements

- For example: Procedures may need to be updated HSE may need to notify a regulatory agency Regulatory agencies or your insurance company may need to review

the change

• If the scope of the project changes, you must submit the changed MOC for review

• Ensure Pre-Startup Safety Reviews (PSSRs) are conducted for changes with HSE impacts

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Questions?