Preliminary Thoughts on Managing Change

Each location handling hazardous chemicals must develop, implement, and consistendy use an effective formal method to confidently deal with change. Many vivid examples of flaws in managing change were described in previous chapters. Effective process safety equipment and procedures must not be jeopardized by cavalier workers or poor quality modification schemes. 

No recipe or procedure can be devised that would be universally acceptable. The exact approach used to scrutinize a proposed change must be site specific and developed for that 

You could very easily conclude that nowadays, several years after the OSHA Process Safety Management standard, most companies have similar MOC systems. That is just not true. Most MOC systems are different at each corporation, and somewhat different at each location. Most MOC systems are like snowflakes, most are significantly different in details than the MOC system at the organization down the road. 

To illustrate the point, at a three-hour meeting at McNeese State University s OSHA Support Group in Lake Charles, four major nationally recognized chemical plants and refineries described the details of their MOC systems in November 1997. The four companies described major system differences and about five more attending companies provided information regarding their approaches. There were distinct differences in the review and authorization process philosophy. 

Each chemical plant and refinery must adopt or develop a procedure tailored to fit the specific hazards, the available technical resources, the culture of the organization, and any required governmental regulations. It must be practical and workable without undue delays. Keep in mind that a modest MOC system that is regularly used and works is much better than an elaborate, sophisticated system with an impeccable paper trail that is occasionally winked at, bypassed, or sometimes totally ignored. 

No recipe or procedure can be devised that would be universally acceptable. The exact approach used to scrutinize a proposed change must be site-specific and developed for that location. There must be a sustained management commitment to the management of change program since this may require a change in culture within many organizations. 

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