Minimizing Risks & Consequences of Organizational Changes

“We have 8 control room operators. The union says we need 8, but we believe we only need 6. So, we outsourced a staffing study to measure the workload of each position to see if we could consolidate a few positions into a single position and where those responsibilities could be absorbed. This project was an eye opener.” – quote from an anonymous source

We often find underloaded and highly loaded positions spread throughout the organization. In some cases, it makes sense to add responsibilities to a particular underloaded position, and in other cases it might make sense to add a new position to help balance the workload evenly across the team of operational shift workers, to ensure no single position is more overloaded than another.

Many plant leaders believe they know which positions have a lower workload and which have a higher workload. Interestingly enough, they are surprised to see they had it wrong. There is a key factor to investigate but it’s so often overlooked. A particular job position might seem very boring and is easily assumed to be a lightly loaded position, however, when you look deeply at the complexity of the equipment and responsibility of the position during an abnormal event, the position may go from extremely boring to almost impossible to manage by one person. This may not be a position that needs additional duties.

Like everything we do when it comes to change, we must look at the risks. That is the very reason why we do an MOOC on staffing changes before the proposed staffing change are ever made. MOOC (Management of Organization Change) is a risk mitigation tool. Many companies only look at the workload during normal operations. It may seem one person can do the job of two people when things are running perfectly. But how do you know this person can manage an unpredictable failure? A staffing MOOC will ensure that during abnormal events, the person on duty can safely manage and control the situation when things amp up. This is a when a staffing change is considered. You first do a staffing study to measure the workload across all positions. You study all positions, that way you can find the spots where you might be able to combine people and tasks together.  

In its simplest explanation, a staffing study is an in-depth look at the total workload for a particular job position. In many cases, a workload study is used to measure the workload now “as it is” versus what the workload would look like if additional duties and responsibilities were added or in some cases removed. MOOC is a process that identifies, evaluates, documents, and communicates any personnel and organizational changes that could result in an adverse impact on HSE. Organizational changes are varied, subtle, and can have substantial, but hidden impacts on HSE performance.   

(29 CFR 1910.119(l)(1)) 

This standard requires employers to develop and implement written MOOC procedures to address the safety and health impacts of contemplated changes, including organizational changes, as they relate to process chemicals, technology, equipment, procedures, and facilities  Some organizational changes, such as changes resulting from mergers, acquisitions, reorganizations, staffing changes, or budget revisions, may affect safety and would therefore trigger an MOOC procedure. Some examples of these include:

• Personnel changes
• Changes in staffing levels
• Staff experience or responsibilities
• Contracting out
• Policy changes such as budget cutting
• Changes that directly impact PSM covered processes

If organizational changes include changes to process chemicals, technology, equipment, procedures, or facilities, a change management procedure would be required to ensure that resulting changes are managed and implemented in a manner that assures continued safe operations. Our company has developed a Management of Organizational Change procedure that we use after the staffing study and positions have been nominated for change. We train the safety manager on how to use it and we leave it with the client to use for future organizational changes.

When the number of employees operating a process is reduced, operators may not be able to continue the implementation of operating procedures. Budgetary changes can have a similar effect. For example, a significant cut in a maintenance department’s budget could require an employer to alter the timeliness or frequency of tests, inspections, repairs, or replacements may impact the workload on a particular position. It is best to score the position to ensure the workload can be managed and then use the MOOC procedure to ensure safety is not compromised during abnormal situations. Some organizational changes may not trigger PSM MOOC. Organizational changes that have no relationship to plant-level PSM processes, as in the case of changes to corporate or administrative personnel whose duties do not relate to operations or maintenance functions, do not trigger PSM MOOC procedures. It’s very important to know which positions require the use of the MOOC procedure.

Some companies have been issued a citation for a violation of 29 CFR 1910.119(l) whenever an employer has made a change, or is in the process of making a change, to process chemicals, technology, equipment, procedures and facilities, without having established or implemented written procedures to manage the change. As discussed above, this applies to such changes when they result from organizational, personnel, or responsibilities changes. A citation can also be issued if a MOOC review has been performed in response to an identified hazard, but necessary safety actions have not been performed in a timely manner to control the hazard. Just following the MOOC procedure is not the end. MOOC results should be reviewed by a team and action items with assigned manager sign off should be implemented.

It is also important that the MOOC procedure address all of the considerations listed in 1910.119(l)(2), that the employees involved in the process are trained in accord with 1910.119(l)(3), and that related process safety information and operating procedures are updated as appropriate in accord with 1910.119(l)(4) and (l)(5).

Many organizations operating hazardous facilities use management systems to effectively address Health, Safety and Environmental (HSE) issues, including process safety. Over the years, failure to properly manage change has been a common root cause of major accidents at industrial facilities – both onshore and offshore. More recently, the industry has recognized that organizational changes have had significant, yet hard to see, effects on HSE performance that have contributed to major accidents. Organizations must identify potential change situations and ensure that new hazards are not unknowingly created or that the risk of existing hazards are not inadvertently increased beyond acceptable levels. Proper understanding of the MOOC program can significantly reduce accidents. The Contra Costa County (Calif.) Safety Council described requirements for OSHA covered processes to have a MOOC program. The main requirements in their ordinance cited in Chapter 7: Management of Change for Organizational Changes (MOOC). These includes, forming a change team or MOOC team, defining the existing situation and identifying affected areas, developing the technical basis for the change, assessing the impact of the Organizational Change on Safety and Health, and completing the MOOC using the MOOC procedure. The UK Health and Safety Executive (HSE), the equivalent of OSHA, invested research into understanding MOOC from a best practice perspective. Part of this research involved studying how console operators deal with organization pressure, fatigue, and abnormal situations.

Some examples of organizational change types are:

• Organizational reporting structure
• Adding, removing, or combining staff positions
• Modifying the location, communication, or time allocation for people
• Job competency changes
• Resource allocation
• Policies and systems

Our MOOC training course describes the essential features of the MOOC process:

• Recognizing MOOC situations
• Types of organizational changes
• General MOOC hazard review approaches
• Understanding the methodology
• Following the procedure

The MOOC study is very similar to a HazOp study with similar participation. Essential to the study are field and control room operator’s with experience in all jobs. Considerations for your process safety manager are:

• Attending a workshop on the MOOC methodology and procedure
• Highlight and discuss potential staffing changes
• Learn how to be self-sufficient with the MOOC procedure
• Include access to HazOp studies for specific areas of interest and include someone familiar with them
• If you have any past incidents that were challenging on resources, they would be excellent to review.
• Come up with scenarios that can challenge the operators while they bring the units to a safe state

During the MOOC workshop, we will review how the existing staffing brings a unit to a safe state the how a new staffing arrangement will achieve the same goals without dropping any tasks or creating an undesirable timeline. Attendees that can for the MOOC team are:

• Process Engineer
• Supervisor
• Field Operator
• Control Operator, Supervisor
• Union Rep.
• PSM Coordinator
• Training rep

If you have a MOOC procedure or want to develop one, we can assess your methodology or provide you with ours. Safety risks and organizational changes are directly linked, and if we do not fill the gap with a solid management of organizational change strategy, eventually an operational staffing change will be made and one of your people will be in a very bad life altering situation.

 

By: Stephen Maddox