As the provider of the world’s leading technology platform for EHS and Operational Risk Management (ORM), the convergence of EHS and Operations is a topic that we talk a lot about.
We have produced many whitepapers, webinars, and blog posts, and I always remember one. It is a blog post published in December 2019. The post, Breaking Silos by Bringing EHS and Operations Together, talks about how we organized a meeting that brought together EHS and operations leaders of a major oil and gas customer. This meeting was remarkable because, despite being at the same company for many years, several of the professionals met each other (in-person) for the very first time!
The fact that the company was using a single EHS and ORM digital platform helped to break siloes and bring EHS and Operations together.
There are probably many instances out there where EHS and Operations are not working together as much as they should. Similarly, there are many examples of how a platform like Enablon helps to create greater opportunities for both departments to work together in order to improve safety and productivity. This post focuses on Management of Change as an example.
Beyond Process Safety ManagementSay “Management of Change” to a professional in Oil and Gas, Chemicals, or Industrial Manufacturing, and most of them will associate it with OSHA’s Process Safety Management standard, and rightly so. Management of Change (MOC) is not some buzzword, it’s an actual term from regulation (paragraph 1910.119(l)). OSHA defines 14 elements of a PSM program, and MOC is one of them.
Yet this is where perceptions should change. MOC should not be seen strictly within the context of PSM, but rather as an enterprise-wide process designed to reduce risks in all situations, not just those involving highly hazardous chemicals where there are risks of unexpected releases of toxic, reactive, or flammable liquids and gases.
Change Creates Risk
Any change creates some form of risk, whether it’s a change in equipment, personnel, products, procedures, or a change to the design of a plant floor. The risk can materialize into a worker injury, property damage, lost productivity, or worse, a catastrophic accident.
When a new equipment is introduced, there is a risk that workers don’t use it properly because they’re not familiar with it, creating a risk of an incident.
When an engineer retires and is replaced by someone with less experience, there is a risk that not all knowledge is transferred to the new engineer who may not be aware of critical information to perform the job safely.
When a cleaning product or industrial degreaser is replaced, there is a risk that requirements associated with the new product (PPE, disposal methods, etc.) are not properly communicated and followed.
And the list goes on.
Digital MOC Brings EHS and Operations Together
Change creates risk. A risk can materialize into an incident. But a risk can also create an opportunity for improvement. A digital MOC system not only helps to reduce risks, but it also contributes to make EHS and Operations work together more effectively.
Management of Change software includes workflows to ensure that actions are coordinated across different departments. In addition, digital MOC records can be shared across the company, unlike paper-based ones, thus further contributing to enhanced cooperation between different teams.
The key to bringing EHS and Operations together is to make sure that workflows and checklists are automated and specific actions are triggered based on the type of change being requested or implemented. Leading MOC solutions are equipped with such out-of-the box workflows, while offering the ability for companies to configure their own workflows.
Let’s look at a few high-level examples.
First, an operator wants to add an additional task to his regular work. He submits an MOC request, which triggers a review of the Job Safety Analysis (JSA) of that particular job. The EHS department is automatically notified to conduct a risk assessment of the task and update the JSA. Additional control measures are then included in the updated JSA and communicated to the operator.
Second, an operations team wants to use a new equipment and enters an MOC request. The EHS team is automatically notified to organize a training session for workers on how to operate the equipment safely.
Third, a supervisor wants to change the layout of a work area by introducing some new machines and moving around some workstations. When the MOC request is entered, the EHS team gets notified to conduct a COVID-19 exposure assessment. The EHS team may have to assess whether the changes impact social distancing rules (2 meters between each employee, need for extra plexiglass dividers, etc.), whether the maximum capacity of that particular work area is impacted, and whether there are any potential impacts on air quality (e.g. need for different indoor air filters if there are more people in the area).
In summary, it’s time to look at Management of Change as a key business function, not just as one element of Process Safety Management. Digital MOC not only reduces risks of incidents, but it also helps to improve collaboration between EHS and operations teams.