counter actions

Program Development Peer-Reviewed

Management ofC

Examples From Practice By Fred A, Manuele

Management of change (MOC)is a commonly used technique.Its purpose is to: •Identify the potential consequences

of a change. •Plan ahead so that counter actions

can be taken before a change occurs and continuously as the change progresses.

With respect to operational risks, the process ensures that:

•Hazards are identified and analyzed, and risks are assessed.

•Appropriate avoidance, elimination or control decisions are made so that acceptable risk levels are achieved and maintained throughout the change pro- cess.

•New hazards are not knowingly in- troduced by the change.

•The change does not negatively af- fect previously resolved hazards.

•The change does not increase the severity potential of an existing hazard.

This process is applied when a site modifies technology, equipment, fa- cilities, work practices and procedures, design specifications, raw materials, or- ganizational or staffing situations, and standards or regulations. An MOC pro- cess must consider:

•safety of employees making the changes;

•safety of employees in adjacent work areas;

•safety of employees who will be en- gaged in operations after changes are made;

•environmental aspects; •public safety;

Fred A. Manuele, P.E., CSP, is president of Hazards Limited, which he formed after retiring from Marsh & McLennan where he was a managing director and manager of M&M Protection Consul- tants. His books include Advanced Safety Management: Focusing on ZIO and Serious Injury Prevention, On the Practice of Safety, Innova-

•product safety and quality; •fire protection so as to avoid prop-

erty damage and business interruption. OSHA’s (1992) Process Safety Man-

agement Standard (29 CFR 1910.119) requires that covered operations have an MOC process in place. No other OSHA regulation contains similar re- quirements, although the agency does address MOC in an information paper (OSHA, 1994). Also, this subject is a requirement to achieve desig- nation in OSHA’s Voluntary Protection Programs.

Establishing the Need Three studies establish that

having an MOC system as an element within an operation’s risk management system would serve well to reduce serious injury potential. This author reviewed more than 1,700 incident investigation reports, mostly for serious in- juries, that support the need for and the benefit of an MOC system. These reports showed that a significantly large share of incidents resulting in seri- ous injury occurs:

•when unusual and non- routine work is being per- formed;

•in nonproduction activities; •in at-plant modification or

construction operations (e.g., replacing an 800-lb motor on a platform 15 ft above the fioor);

IN BRIEF •Studies and statistics indi- cate that an effective man- agement of change (MOC)/ prejoh planning compo- nent within an operations risk management system reduces the potential for serious injuries. •Specific guidelines from practice can help SH&E professionals initiate and utilize an MOC system. •Real-world examples of MOC systems in place for other than chemical opera- tions are discussed (and availahle through PS Extra). SH&E professionals can reference these examples when developing an MOC system to suit particular operational needs.

fions in Safety Management: Addressing Career Knowledge Needs, and Heinrich Revisited: Truisms or Myths. A professional member of ASSE’s Northeastern Illinois Chapter and an ASSE Fellow, Manuele is a former board member of ASSE, NSC and BCSP.

^ JULY 2012 PfofessionalSafety 3 5

Having an effective

IVIOC sys- tem wiil

reduce the probabiiity of serious

injuries and fataiities.

3 6 ProfessionalSafety

•during shutdowns for repair and maintenance, and startups;

•where sources of high energy are present (elec- trical, steam, pneumatic, chemical);

•where upsets occur (situations going from nor- mal to abnormal).

Having an effective MOC system will reduce the probability of serious injuries and fatalities occur- ring in these operational categories.

A 2011 study by Thomas Krause and colleagues produced results that support MOC systems as well. Seven companies participated. Shortcomings in prejob planning, another name for MOC, were found in 29% of incidents that had serious injury or fatality potential. Focusing on reducing that 29%, a noteworthy number, is an appropriate goal. (Data based on personal communication. BST is to pub- lish a paper including these data.)

In personal correspondence, John Rupp of United Auto Workers (UAW) confirmed the continuing his- tory with respect to fatalities occurring in UAW-rep- resented workplaces. According to Rupp, from 1973 through 2007, 42% of fatalities involved skilled- trades workers, who represent about 20% of UAW membership. Rupp also reported that from 2008 through 2011, 47% of fatalities involved skilled- trades workers. These workers are not performing routine production jobs. They often perform unusu- al and nonroutine work, in-plant modification or construction operations, shutdowns for repair and maintenance, start-ups and near sources of high en- ergy. An MOC (or prejob planning) system would be beneficial for such activities.

Assessing the Need for a Formalized MOC System Studying an organization’s incident experience

and that of its industry can produce useful data on the need for a formalized iVIOC system. Workers’ compensation claims experience can be a valuable resource as well.

To develop meaningful and manageable data, an SH&E professional should execute a computer run of an organization’s claims experience covering at least 3 years to identify all claims valued at $25,000 or more, paid and reserved. If experience in other organizations is a guide, this run wül likely encom- pass 6% to 8% of the total number of claims and 65% to 80% of the total costs.

Data analysis should identify job titles and inci- dents that have occurred during changes, and indi- cate whether a formalized MOC system is needed. Industry experience that may be available through a trade association or similar industry group also should be reviewed. Finding that few incidents resulting in serious injury occurred when changes were being made should not deter an SH&E pro- fessional from proposing that the substance of an MOC system be applied to particular changes which present serious injury potential.

Experience Implies Opportunity To test whether personnel in operations other

than chemical sites had recognized the need for and developed MOC systems, the author queried

JULY 2012

members of ASSE’s Management Practice Special- ty. The response was overwhelmingly favorable, and the number of example documents received was more than could be practicably used.

Examples received demonstrate that manage- ment in various operations has recognized the need for MOC systems. Eight systems selected from this exercise and two previously available are presented as examples in this article. Due to space restrictions, of the 10, one is printed on p. 41, and all are posted at

These select examples show: •the broad range of harm and damage categories

covered; •similarities in the subjects covered; •the wide variation in how those subjects are ad-

dressed. These examples reflect real-world applications

of MOC in nonchemical operations. They display how such systems are applied in practice.

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