What is “Management of Change?”

| July 18, 2007

Although it is often used as a term of art in the safety field, “management of change” is not a defined term in OHSAS 18001:2007.  It is, however; vital to an effective OH&S management system. 

Explicit requirements for management of change were added into section 4.3.1 of OHSAS 18001 in the 2007 revision of the standard.  This addition was an explicit request of the American Industrial Hygiene Association for purposes of aligning OHSAS 18001 with the U.S. Occupational Health and Safety Management System standard — ANSI/AIHA Z10-2005.  In addition, management of change is also an explicit requirement for safety management systems implemented to comply with the Seveso II Directive (see Annex III of EU Council Directive 96/82/EC).

 The following requirements related to management of change were added in section 4.3.1:

 The procedures for hazard identification and risk assessment shall take into account:

g) changes or proposed changes in the organization, its activities or materials; h) modifications to the OH&S management system, including temporary changes, and their impacts on operations, processes and activities;…. For the management of change, the organization shall identify the OH&S hazards and risks associated with changes in the organization, the OH&S management system or its activities, prior to the introduction of such changes. 

In addition, reference to Management of Change was also included in section 4.4.6: 
The organization shall determine those operations and activities that are associated with the identified hazard(s) where the implementation of controls is necessary to manage the OH&S risk(s). This shall include the management of change (see 4.3.1).

These new requirements cover four important concepts:

  • Identification of the hazards associated with “change”
  • Assessment of the risks associated with “change”
  • Consideration of OH&S hazards and risks prior to the introduction of the “change”
  • Implementation of the controls needed to address the hazards and risks associated with the “change”

For purposes of management of change within an OH&S management system, the changes that need to be addressed include:

  • Organizational changes (e.g. personnel or staffing changes)
  • Activity changes (e.g. changes to processes, equipment, infrastructure, software)
  • Material changes (e.g. new chemicals, packaging)
  • Changes to the OH&S management system (e.g. procedures)

Why is management of change so important?

Ineffective management of change is one of the leading causes of serious incidents.  To quote the U.S. Chemical Safety and Hazard Investigation Board (CSB), “In industry, as elsewhere, change often brings progress.  But it can also increase risks that, if not properly managed, create conditions that may lead to injuries, property damage or even death.” (from CSB press release announcing its 8/28/2001 Safety Bulletin concerning “Management of Change”)  Ineffective management of change is one of the major contributing factors in many of the incident investigations conducted by the CSB.  To check it out, go to the CSB web site at http://www.csb.gov  and enter “management of change” as your search term at the link “Search this Site.”

© ENLAR® Compliance Services, Inc. (2007)

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Category: Emergency Preparedness, OHSAS 18001:2007 Revisions, Risk Management

Comments (1)

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  1. Bob Westly says:

    Thea – The conversation we had regarding what constitutes a “change,” who’s responsible for assessing the change, and how this gets done in the context of reassessment was enlightening. The question I raised to you was how does an organization decide a sufficient change has occurred to warrant reassessment of aspects and/or risks. This question came up in the context of a major international industry’s significant challenges in various types of changes occurring at various times and locations around the globe. Basically, the question was: “How small a change is not a change?” A follow up question was: “How does one determine if a change needs a reassessment without actually doing the reassessment?” We agreed that apparent size of the change is essentially meaningless relative to potential effects on aspects and/or risks. Regarding who’s responsible, you indicated in your experience there does need to be a responsible person in the organization, typically the EHS director, who is competent to review the “change” and decide if reassessment is warranted. Following our discussion on these issues, I held a teleconference with one of the non-US business units of the international industry and reviewed this with their EHS management team. They were in wholehearted agreement, had implemented procedures in basic agreement with the above, and even pilot tested their procedure in advance to assure its effectiveness. I did discover that they were not aware of the experience of the U.S. indicating that lack of proper management of change is a major contributor to safety incidents. They plan to research this discovery a bit more, which I suspect will be used to further improve their management of change procedures.