Recognizing Change, and Knowing Who to Tell
Implementing Management of Change procedures at your facility can help prevent incidents.
- By Karen D. Hamel
- Aug 01, 2022
With the familiar adage, “Change does not come easily,” so widely believed to be true, it would stand to reason that when a change does happen, people would immediately recognize it and call it out—no matter how small. Yet, small changes in a workplace often go undetected. Perhaps even worse; when they are recognized, they go unreported.
Facilities subject to OSHA’s Process Safety Management (PSM) Standard are required to have a written Management of Change (MOC) Program for all processes that involve hazardous chemicals that are subject to standard 29 CFR 1910.119(l). But, for facilities that are not subject to this particular regulation, implementing MOC procedures as a best practice and teaching employees how to recognize anything new or unusual, as well as how to report any changes they have noticed, are leading indicators that can help prevent incidents.
It can be easy to dismiss change management by saying that changes will be caught during audits. Audits are, indeed, one tool that helps facilities determine if their processes and procedures are being followed. However, some changes aren’t directly related to a written process. And since it isn’t practical for most facilities to conduct a complete facility audit every single day, teaching employees to recognize changes as well as who to report those changes to are important factors in reducing hazards and risks.
Chemicals
In facilities that use a wide variety of chemicals, it can be a full-time job to review all of the Safety Data Sheets (SDSs) that are forwarded from the purchasing and receiving departments to ensure that nothing has changed since the last order. If procedures are not in place to prevent it, it can be another full-time job tracking down SDSs and conducting training for chemicals that people bring to the worksite with them.
Untrained employees may not consider the consequences of changing out a chemical that is routinely used with a household chemical that they brought from home (such as cleaners and solvents) or with a chemical that is used somewhere else in the facility. This sometimes results in unlabeled containers or worse, unsafe conditions caused by an unintended chemical reaction or chemical exposure.
As part of hazard communication training, teach employees to recognize containers that are unfamiliar or that are not properly labeled. Consider also discussing the potential hazards that household chemicals or chemicals brought from other areas could create in the workplace as well as how to properly—and safely—obtain all chemicals that they need to do a particular job.
This article originally appeared in the July/August 2022 issue of Occupational Health & Safety.