Few days back AIChe has released a monograph on how to implement Management of Change practices during the Covid – 19 scenarios. It was broadly defined for RBPS for Disruptive Times. It contained many items and for the first time it included human factors as part of overall process safety culture. The RBPS included may key items for PSM Components. Some of the items under Process Safety Culture include Lead the crisis response, communicate often, compensate for benefits for human performance, build trust and maintaining a sense of vulnerability amid the crisis. It also included under manage risk section, the key components like use risk-based assessment, continue inspection testing and preventive maintenance. Under management of change section, it included Continue to manage change and recognize organizational change is key and anticipate organization change.
Management of change is a practice aimed at ensuring safety, health and environmental risks are properly controlled within a organization. In order to achieve the aim and ensuring that new hazards are not introduced, and existing hazards does not increase, necessary changes are made to operations, personal or facilities. There are many regulatory guidelines available which detail out the requirements for carrying out management of change like the OSHA PSM standard. One of the requirements of PSM 1910.119(1)(1) is employer shall establish and implement written procedures to manage the changes to process, chemicals, technology, equipment and procedures and changes to facilities that effect all covered processes. Some of the best practices which are mentioned in literature include identifying potential change situation, evaluating the possible impacts, decision to carry out the change or not, risk controls and follow through the change and finally maintaining a dependable practice.
The overall business follow for carrying out a complex management of change in current situations might start with identifying a need for changes, carrying out initial review of the change, with the help of multi-disciplinary team carrying out classification of review, followed by multi-disciplinary hazard review, completing pre-implementation tasks which require authorizations for completing the tasks, changes authorization and completion of post implementation tasks. Most of the times it is recommended to keep the Management of Change process simple it has many gaps like in adequate definition of change, lack of integration to other PSM elements, lack of clarity on roles and responsibilities and finally very loose tracking of action items and their follow up.
Some of the IT requirements for effectively managing the Management of Change include i. Identification of responsible personal and automatic assignment of members based on specified work area or job or function, identification of appropriate approvals mechanisms and by passing the approvals based on business decision, automatic generation of action items based on responses to questions, ensuring all tasks are tracked to completion and change records are not closed unless tasks are completed and finally ability to check the change log of each change management or activity steps when a task is completed. Besides these core requirements an effective Change Management must include performance improvement functions like ability to management varied changes like temporary or permanent, actions tracking centrally for all type of activities whether created from within the application or external to it, email notifications to members of the assessment, management review support capabilities like reporting and KPI tracking like backlog of MOCs, number of MOC performed and staff hours etc.
There are many software vendors available in the market who give the ability to carry out Enterprise level Management of Change processes. Many of the vendors have tools which are majorly spreadsheet like data entering tools in which each change needed to be manually created with adding of change type, adding responsible members, creating actions manually and following up questionnaire and closing the requests. There are other software tools available like SAP S/4 HANA Management of Change, which offer functionalities like Automatic Change request task creation, Personal integration based on job roles or partners or even Digital signature abilities etc.
Some of the capabilities of SAP Management of Change for meeting the RBPS analysis for Disruptive times include – Ability to define a Change requirement type specifically suited for carrying Disruptive Management of change under Type of Change Request. The change request can have a dedicated status network which can be custom defined like setting up of Status network. It might include a status cross checks set up based on change request. For the specific disruptive management of change can include a specific activity templates like Risk Assessment, HSE Impact assessment, Quality Impact Assessment, Environmental Impact Assessment, followed by training requirements etc.
The activity type gives ability to set up various activities like questions, notifications, tasks etc. in the current context it can be declared a question answer type like Develop and Execute BCP plan, Set up ability to work remotely and detailed requirements there in. Some of the tasks type activities can be set up like Communicating with employees often to ensure bulletin boards, toolbox talks etc. Other activities which can be set up include tasks for employee wellbeing questionnaires. That is all the sections underlined in section Process Safety Culture can be defined as a list of check list including Lead crisis management, communicate often, compensate for impacts on human performance, build trust and maintaining sense of vulnerability amid crisis. A management of change for workforce involvement type of activities can also be carried out like engaging creativity etc. If specific HR object needed to be integrated necessary changes can be included in the software component.
Definition of partner roles gives the ability to declare specific task force members who are responsible for carrying out the management of change like specific job role or introduced to meet the Disruptive situation. The requirement for the situation includes ability to integrate with varied object types like BOM, Customer, Equipment, Function Location etc. While setting up change request necessary reference or main objects can be set up and they can be referenced while working with the change request. Based on the answers to the questions which are declared in the activities necessary activities can further be triggered to carry out the change. There is a concept available in the module which is called business rules framework which can be used to automatically identify partners for activities or change requests.
To conclude Covid – 19 has given us an unprecedented challenge in terms of coping up with process safety due shortage of man power, disruptions and employee morale and audit processes and incidents while any Covid – 19 cases are identified within an enterprise. It needs a holistic IT process tools which can interact with all the PSM components effectively like Incident Management, Audit Management, Compliance process, Asset Integrity, Training and HR besides core SHE Functions and key expertise. These integrated approach will help a lot in the reduction of human loss, process disruptions and more importantly catastrophic events.