Drive Effective EHS Change Management with On-Demand Chemical Property & Safety Data

Working with Chemicals
December 05, 2019

Change Management is a thriving topic in the world of Environment, Health and Safety (EHS) as organizations across the globe deal with the risks presented by accelerating change. Over the past 30 years business environments have become fragmented, global, digital, customizable, and more agile than ever before.

According to the Project Management Institute (PMI), today’s business environment is characterized by rapid change and the forces of change are driven by both external and internal factors. The external environment includes such forces as rapid technology advancement, increased globalization, political and regulatory currents, innovation, and shorter product lifecycles, and the list goes on. The internal drivers of change include the need to drive costs down through better efficiencies to improve bottom-line results, pressures to accelerate growth, and the need for higher levels of organizational agility. Adapting and embracing these forces of change requires ongoing organizational change which adds its own management issues.

This increasingly dynamic environment means organizations must be agile in their use of technology and resources to evolve and change as the paradigm shifts. Successful companies and leaders will be determined by how fast the organization or individual can adapt. The requirement is there to process, accommodate and make decisions around the ever-mounting pace, magnitude and volume of data coming in from the organization and market.

Chemicals and Change Management

Consequently, this rapid change impacts an organization’s ability to keep up with the demands of chemical management. Fundamentally, as the organization grows and evolves, one major category of risk is around the maintenance, use and disposal of chemicals. On-demand chemical property and safety data is imperative to understanding the risk posed to an organization’s workers, communities and customers they serve. Processes are formed and personnel is staffed based on an organization’s process risk mitigation. This strategy must include some type of management of change.

Too often organizations are caught off guard by a personnel departure or lack of documentation that leads to serious exposure for the organization. Inconsistent change management practices – especially around chemicals – increase risk and can lead to incident and property damage.

The U.S. Chemical Safety  Board (CSB) has been tasked with investigating major chemical process-related incidents since becoming operational in 1998, and falls under the authority of the Clean Water Act Amendments of 1990. Having investigated nearly 100 such incidents, the CSB has developed more than 800 recommendations to improve safety of operations at these types of facilities. The CSB regularly notes that organizations need to improve upon their Process Safety Management (PSM) systems, as well as enlist key components related to management of change.

While PSM standards are enforced by OSHA and are a key component of EPA Risk Management Plan (RMP) Rule requirements, government oversight alone is not enough for preventing disasters at facilities. It is up to the organization to elevate their PSM to ensure their workers and communities are protected from disastrous incidents that can have far reaching consequences.

Reducing Process Safety Risks

Fortunately, the Enablon Management of Change (MOC) software solution combined with Verisk 3E’s Chemical Property & Safety Data enables companies to manage and reduce process safety risk, ensuring regulatory compliance and reducing their environmental and safety hazards. Enablon’s MOC solution allows companies to manage changes to procedures, processes, equipment, products and more when coupled with Verisk 3E’s Chemical Property and Safety Data. This mitigates risk while ensuring proper procedure methodology and regulatory compliance.

Changes occur every day, furthering the importance of on-demand data and a system that can handle the scale of data collected. The union of Enablon’s MOC and Verisk 3E’s Chemical Property and Safety Data ensures that your team is using the most recent data while defining or changing processes and procedures.

Management of Change is a central component for any PSM system. In recognition of this, both OSHA and EPA specifically require facilities to manage changes to covered processes through a formal MOC program. The CSB has gone so far as stating that processes not usually considered critical to compliance in a PSM should be considered “good practice to do so, irrespective of the specific regulatory requirements.”

To ensure that a clear MOC program is established and adopted by all, facility operators must establish and implement written procedures to manage changes to chemicals, technology, equipment and procedures. Changes must also be made to facilities that affect covered processes.

Organizational changes such as mergers and acquisitions, reorganizations, staffing changes or budget revisions that affect a covered process should also trigger MOC requirements. In most cases, if an organizational change directly or indirectly necessitates changes to a covered process, the best practice is to require an MOC procedure to ensure changes are implemented in a safe manner.

For each process change, organizations must consider:

  • Technological implications
  • Impact to the health and safety of workers and the communities they serve
  • Necessary modifications to operating procedures
  • Time period of the change
  • Authorization requirements for the proposed change

The Importance of a MOC Program

Management of Change is becoming an increasing challenge with fast-growing global industries and workforces. The need for rapid product development due to accelerating customer demands requires that companies are agile when managing their core processes. The ability to safely acquire, maintain, use and dispose of hazardous chemicals within the organization is paramount to much of the new products being designed. As a result, having access to quality chemical property and safety data is important to continued compliance and the safety of workers and the environment.

When decisions and changes are made rapidly, the Washington State Department of Labor and Industries cautions, “Safety and health risks can increase, resulting in disasters such as explosions at the oil refinery and detergent plant described in the U.S. Chemical Safety and Hazard Investigation Board’s 2001 ‘Management of Change’ safety bulletin.” Unfortunately, there are many other notable examples of simple changes at a worksite that led to tragedy.

In worksites where highly hazardous chemicals are used, the PSM rules must apply. Proper application of Management of Change is not just a best practice but a prerequisite. In such cases, a MOC program is used to ensure all process changes are properly reviewed and any hazards introduced by the change are identified, analyzed and controlled before resuming operation.

Whether you are seeking to establish, improve, or manage a MOC program, the Enablon and Verisk 3E combined solution provides an integrated Management of Change resource that delivers the best chemical property and safety data for the processes which are being created, changed and ultimately managed.

Author

Alan Johnson Portrait

Alan L. Johnson

Director of Portfolio Management and Strategic Alliances, Verisk 3E