Management of Change Part 2 - Diving Deeper

In the last post, we reviewed a case study of a manufacturing process change where the principles of change management were not effectively implemented.  In this post we will dive deeper into the process of Management of Change (MOC).

What is Management of Change?

According to the ISO45001 Safety Management System standard, Management of Change is a systematic way to handle changes within an organization to effectively deal with the change and to capitalize on possible opportunities.  This process involves adapting to the change, controlling the change, and effecting new change.  This definition leads to our next question:

What is Change?

What is change, really?  The Cambridge online dictionary states that change is to exchange one thing for another thing, especially of a similar type and to make or become different.  James Baker once stated the following:  When initiating change remember, people support what they create.”  The “6P” rule is very important in change: “Prior Preparation Prevents Poor Performance”. Sometimes we don’t recognize that our action is resulting in a change, somewhere.  You may not plan or intend to make a change, but your actions can create or result in a change.  “Make a Change, Expect a Change” is a commonly stated mantra in industry.

Some changes may not be obvious to the originator of the change; however, the results can affect quality, safety, environmental, and manufacturing equipment reliability and result in production delays, extra cost, regulatory violations, product and equipment damage, and injuries.

What are the requirements for Management of Change? 

Most frequently we see MOC applied in a Process Safety Management (PSM) process as required by OSHA to protect employees from unforeseen consequences of a change.  EPA has a parallel MOC requirement designed to protect the public and the environment from the unforeseen consequences of a change.  There may also be contractual requirements to follow some form of MOC process when making design or manufacturing process changes.

ISO 9001: Quality Management Systems, AS 9100: Quality Systems - Aerospace - Model for Quality Assurance in Design, Development, Production, Installation and Servicing, and ISO 45001: Safety Management Systems standards each include change management expectations throughout all aspects of business including management processes, design and production. These management systems focus heavily on the Plan-Do-Check-Act (PDCA) model. However, when it comes to changes, sometimes we stop half-way (Plan and Do) and do not follow up to see if the results of the change were as planned and expected (Check and Act). 

Why do some organizations fail to apply MOC?

Some people balk at the idea of management of change because they feel it over-complicates and slows down the process.  There is a perception that change management takes too much time and effort and is not value added – however in project management, agile and other lean methodologies, change management is seen as key to stay in scope, on schedule and in budget. In my experience, one of the biggest reasons is the lack of awareness of the impact of the change.  The person planning the change may be unaware of the potential environmental consequences, for example. The group advocating for the change may believe that the change is a minor one, it does not impact “form or function”, but even minor process changes can result in unintended consequences.  Others feel that the change does not change the product, we don’t need to review it.  However, changes in staffing and scheduling can impact facilities and equipment, and changes in layout or flow can impact safety. Often, we think we are good communicators, and assume everyone is aware of the change.  You should never assume that everyone who needs to know about the change is fully informed. Sometimes we are afraid to over communicate, include too many people, and complicate the process.  This is a valid concern and requires planning to ensure key stakeholders are included. 

Don’t neglect your Stakeholders-

They could be anyone! Don’t forget to look at the support processes and organizations who may not be directly involved in the change itself but could be impacted.  Safety and environmental groups often are left out of the change conversation until very late in the process.  For example, in the case of any change involving chemical use, quantity, or application methods, such as changing from a roll coating application to a spray coating application, there could be environmental permitting consequences which are expensive and time consuming.  A new source permit could take a year or longer to get approved depending on the chemical.  In this example, there are also changes to the level of personnel exposure to the chemical.  Further, some may not consider that this type of change could require revision of the area’s electrical hazard classification due to the increased presence of flammable vapors.  This change could impact infrastructure, fire and life safety requirements, and insurance risk level. 

MOC Tools

One tool does not fit all types or levels of change.  The tool you use will depend on what change is being considered and at what level the change is being performed.  For example, a process flow map, turtle diagram or fishbone diagram all are tools that can help identify stakeholders. Management of Change does not have to be complicated. In PSM a flow for change starts with recognition of the change and several hazard identification and risk assessment steps prior to pre-startup safety review, implementation of the change and training.  The last step is always the Check & Act steps from PDCA.  There are several tools used in the management of change process.  In our next post, we will review some of the available tools to help support and streamline the MOC process.