SEMS Element 4 – Effective Management of Change

Now that we have discussed what BSEE expects to be some of the Management of Change (MOC) initiating actions, let’s discuss how your MOC process should be structured. In my opinion, the steps I have outlined below will help drive your program to success.

Step #1 should be to facilitate a hazard analysis for whatever the initiating action is. You must consider the impact the change will have on safety, health, and the coastal and marine environments. As mentioned in a previous blog, I recommend using API 14J for your hazard analysis methodology. It is the only hazard analysis document referenced in the 30 CFR and is also referenced in the API RP 75.

Step #2 would be to create a risk register for each item identified in the hazard analysis. Depending on the scale of the change you are managing, that register could contain a few items or numerous items. Using the hierarchy of controls, work your way through the register.

Step #3 should be to effectively communicate the reasons for the change to all involved stakeholders. Included in that communication should be the benefits of successful implementation. Adequate communication of the details of the change will be very important. The better you perform this step, the less likely you will have an unplanned or unidentified problem later. Things like:

a)      When it will be initiated?

b)      Who is involved?

c)       Why is the change necessary?

d)      What is the technical basis for the change?

e)      Define the necessary time to implement the change.

f)       Set objectives and goals for the change.

Step #4 would be to start implementing any additional training programs that you identified as necessary as a result of the hazard analysis and risk register process. You definitely want to have your personnel trained up and ready to go for your pre-startup review.

Once step #5 is completed or as you are completing it, depending on the training required and the current competency level of the personnel involved, you can start to utilize that new SEMS II required employee participation program. You may have started involving some of those employees already. Since you need to create/ revise operating procedures and operating manuals, maintenance schemes, etc. their immense competency in the actual operation will come in handy. The 30CFR requires any procedural changes to be well documented. So hopefully your SEMS program has a documentation identification, review and approval process to follow.

The 30CFR requires step #6 to be a review of all changes prior to implementation. This is a separate review from the Pre-Startup Review. We will discuss pre-startup review in a later blog series.

Once that is completed, step #7 is to initiate the management approval process.

Now you are ready to actually perform the work. And with the employees all trained up and working the plans that they helped to develop, the operation should go smoothly without any undesirable events.

There is actually one more step in the process that will help prevent those undesirable events. Step #8 is the monitoring of the process through the use of leading indicators. A few leading indicators for this process could be inspections, audits, behavioral observations and performance reviews.

Depending on the type of change you are initiating, you may expand or contract those steps mentioned above. In our next blog we will discuss utilizing the right people for the job.