Recognizing Change, and Knowing Who to Tell

Recognizing Change, and Knowing Who to Tell

Implementing Management of Change procedures at your facility can help prevent incidents.

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. 

Site Security 

Emergency Action Plans should detail different types of emergencies that could happen as well as the plans, exit routes, responsibilities and other procedures to follow during and after an unplanned event. Time is spent training and drilling these procedures so that everyone can get to safety. Time also needs to be spent teaching employees how to assess their surroundings. 

Situational awareness has become an important component of many different types of training. From specific requirements for Department of Transportation Hazmat Employees and employers subject to Chemical Facility Anti-Terrorism Standards Trainings to the more general workplace violence and active shooter trainings that all employers should provide, teaching employees that situational awareness is a continual responsibility will help to keep more than just the building’s perimeter safe.  

One way to incorporate situational awareness into regular routines is to make it part of daily housekeeping efforts. When a facility is clean and clutter is not allowed to accumulate, it is easier for everyone to notice when something is out of the ordinary. Whether it is a mysterious box, package or bag that is out of place, a door that is ajar or the bushes outside are askew, it is more likely to be noticed both during routine housekeeping procedures and throughout the day in clean, uncluttered workspaces.  

Equipment and Technology 

When equipment and technology begin to near the end of their useful life—or worse break down in the middle of a production run—it is easy and sometimes even exciting to start looking for the newest, upgraded model to replace the older or outdated ones. “Bigger” and “newer” are two words that may sound better but should actually signal employees and supervisors to stop and review any potential changes.  

“Bigger” could also mean “louder,” which may necessitate isolating the process or changing hearing protection requirements. “Bigger” may also mean “heavier,” which could lead to more ergonomic issues. “Newer” could mean “more technologically advanced,” which probably means that operators will need to be re-trained before using it.  

The OSHA PSM Standard has some good references for these types of changes. If the new item is a “replacement in kind,” the new item doesn’t necessarily need to be reviewed. A good example of this is replacing a burnt-out light bulb with a new, identical lightbulb. But replacing the burnt-out lightbulb with a different type of bulb would trigger a review process.  

Processes and Procedures 

Similar to equipment and technology, changes to processes and procedures need to be well-communicated and readily recognized. Even well-established processes and procedures that are based on thorough job hazard (and/or job safety) analysis can succumb to unintended changes over time. Sometimes, these changes may be so subtle that they are overlooked until the process or procedure is audited and the change has become ingrained as a new normal.  

Encourage employees to note even the slightest variations on daily inspection forms or operational checklists so that the changes can be tracked and follow-ups can be conducted to determine the cause of the change. One degree of temperature difference or one PSI pressure change may not seem important, but it could indicate premature wear or another type of mechanical problem—especially if it is near the upper or lower ends of an acceptable operating range. 

People 

Long work hours, irregular shifts, family and mental health issues are just a few of the stressors that affect employees every work day. In a recent Colonial Life Survey, on a ten-point scale, 80 percent of workers rated their daily stress level at seven or higher.  

With incidents of bullying, workplace violence, threats and harassment making headlines almost daily, aggressive and undesirable behavior can almost feel like a new normal for many people. It can also make it more difficult to recognize subtle changes in co-workers' behavior. Hybrid working conditions can further complicate this. 

Insurance carriers, Employee Assistance Program (EAP) providers and human resource professionals are all good resources to assist with training to help employees recognize signs and signals of behavioral changes in others. Posting information on how to report this information (anonymously or in person) so that human resources or other designated personnel can follow up can help to encourage everyone to act upon changes that they may notice in others.  

Change may, indeed, not come easily. It is also inevitable. But, when it can be immediately recognized, noted, reported and openly discussed, facilities are better able to avoid costly injuries, illnesses and deaths.  

This article originally appeared in the July/August 2022 issue of Occupational Health & Safety.

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