Controlling Risk by
Managing Change
Jessica Blaydes & Gary Fobare
Honeywell Aerospace
2013 Region IX Workshop
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?
1. To identify and control hazards
• 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
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The Impacts of Change Are Not Always Obvious
Example of Change: Change in Chemical Usage
Change in
chemical usage
New shelf life
requirements
Increased PPE
needs
Different
storage
requirements
Operator
training needs
Effects on
product quality
Increased
hazardous
waste
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Why focus on Management of Change?
2. To maintain compliance
• Regulatory Requirements
- Process Safety Management
• Internal Requirements
- Management Systems
• External Requirements
- Customer Requirements
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Why focus on Management of Change?
3. To keep people informed
• 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
MYTH: A great solution + Effective project management =
Project success
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What Types of Changes Need to be Managed?
“The most difficult part of management of change
is recognizing change.”
• 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?
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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
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
The form should be easy to use but still capture the required
approvals for each potential change impacting the site
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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?
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