OSEA Safety Blog

Manage Change Before Change Manages You

Have you ever heard the statement, “small changes add up to big results”? Whether it’s productivity, financial savings, or personal habits, this is true and most likely welcome. Not to be a downer on change, but through the lens of safety, a small change can add up to a big safety disaster. And that’s why managing change is so important. If you don’t manage change, change will manage you.

OSHA has a standard for managing change for facilities that fall under the Process Safety Management (PSM) of Highly Hazardous Chemicals. These facilities have high risk chemicals on site where a change in a process can be a matter of life and death. Therefore, these facilities are required to have written Management of Change (MOC) procedures.

And it’s not just a change in process that needs to be included. It’s changes to equipment, chemicals, technology, and procedures. The MOC procedure must include descriptions of the technical basis of the change, impacts on safety and health, modifications to operating procedures, the time period necessary for the change, and appropriate authorizations of the changes.

But what about the rest of us – should we be concerned about managing change?

Yes. If you have a change to chemicals or products you are using; any process, equipment, or procedure, you would benefit from adopting your own MOC policy and procedure.

Here are a few examples of change that would benefit from a formal review prior to implementing the change:

Purchase / use of new product.

• Do you have the safety data sheet (SDS)?
• Has it been incorporated in your Hazard Communication Plan?
• Is the SDS on file in the appropriate locations?
• Does this chemical/product require use or change of personal protective equipment (PPE?)
• Does this chemical/product have any special storage requirements?
• Have your employees been trained on proper use and storage of the chemical/product?

What could go wrong if you don’t do the above? Worst case is someone gets hurt.

Changes in Equipment-- i.e. a new forklift that is battery operated rather than propane

• Does the battery need to be removed to be recharged?
• Do you have an eye wash and shower in close proximity to the recharging area?
• Have employees been trained on how to remove and reinstall the battery during charging?
• Do employees have proper PPE available to use during battery handling?
• Have your written plans been updated to include the changes in handling and PPE?

What could go wrong if you don’t do the above? Worst case is someone gets hurt.

Changes to the facility-- i.e. adding a new production line or other physical changes to the facility

• Does the location interfere with any existing emergency escape routes?
• Is there still sufficient width for powered industrial vehicles to safely drive in the area?
• Is there sufficient space for pedestrians as well?
• Will there be a need for additional machine guarding?
• Does the physical change block access to fire extinguishers or electrical panels?

Many of us have lived through Fire, Ready, Aim situations where the idea is to execute the change first, then figure out the details later. (Rather than Ready, Aim, Fire.) This leads to in-the-moment trouble shooting and the risk of injury if hazards are not first identified and then controlled properly. Often, we learned after the fact that even the simplest of changes resulted in needless injury.

Perhaps you never really thought about adopting a formal MOC procedure to make sure any changes to your facility or operations are carefully reviewed by multiple people prior to making the change and formalized in new written procedures and training. It’s never too late to take the time to evaluate changes from all angles, including safety. That way, you will manage the change, rather than the change managing you.