SEMS Element 4 – Management of Change Part 2

Many of the previous SEMSinar™ series blogs and webinars have, in part, prepared your organization for the development of a well-designed management of change (MOC) process. We started off with the organization chart, then came job descriptions and how they relate to training requirements. In the next series we discussed how management should demand accountability, designate individuals and provide resources through policies and procedures. For the SEMSinar™ series #3 blogs we went deeper into training requirements where we learned the difference between regulatory training requirements and your required training. In the SEMSinar™ series #4 blogs, we learned about hazard analysis methodology, the safety and environmental information needed and how to utilize safety alerts for that process. Now let’s look at how all of those items will assist you in successfully assigning the right personnel for the right stage of your MOC program.

In the two previous MOC blogs we discussed what the initiating requirements are as per the 30CFR 250.1912(a), API RP75 and the NTL2011-N09. Your initiating event will determine what subject matter experts will be required to participate in the MOC process.

However, we do know that 30CFR 250.1912(d)(1)(2)(3)(4) states:

 § 250.1912   What criteria for management of change must my SEMS program meet?

(d) The following items must be included in your management of change procedures:

(1) The technical basis for the change;

(2) Impact of the change on safety, health, and the coastal and marine environments;

(3) Necessary time period to implement the change; and

(4) Management approval procedures for the change

When you combine the above regulation with 30CFR 250.1909(f):

§ 250.1909   What are management’s general responsibilities for the SEMS program?

You, through your management, are responsible for the development, support, continued improvement, and overall success of your SEMS program. Specifically you, through your management, must:

(f) Utilize personnel with expertise in identifying safety hazards, environmental impacts, optimizing operations, developing safe work practices, developing training programs and investigating incidents.

You begin to realize the importance of the training you provide, the competency assessments you conduct and the related records of those items.

§ 250.1909   What are management’s general responsibilities for the SEMS program?

You, through your management, are responsible for the development, support, continued improvement, and overall success of your SEMS program. Specifically you, through your management, must:

(i) Ensure that suitably trained and qualified personnel are employed to carry out all aspects of the SEMS program.

In the above regulation, the CFR requires suitably trained and qualified personnel carry out all aspects of the MOC program. This would include personnel in human resources to handle communications, training assessments and job description updating if needed. Subject matter experts, backed up by their training and job descriptions, to handle the technical aspects would need to be engaged. Safety and health professionals as well as environmental engineers, all backed by their training and job descriptions, would also be included. Emergency response plans may need to be reviewed as part of the process. A management review needs to be concluded prior to the work ever beginning.

§ 250.1909   What are management’s general responsibilities for the SEMS program?

You, through your management, are responsible for the development, support, continued improvement, and overall success of your SEMS program. Specifically you, through your management, must:

(c) You must review all changes prior to their implementation.

I feel that you should start refining your MOC program now before your BSEE audit identifies all of those opportunities for improvement (non-conformities). If you don’t have a ‘well oiled’ MOC program in place and the personnel in the right positions as defined by your organization chart and policies/ procedures when your BSEE audit is completed, you will have much difficulty in successfully implementing all of those opportunities for improvement.