SEMS Management of Change: Why One Size Doesn’t Fit All

One of the most frequent requests I have been getting from customers is for help with Management of Change policies under SEMS.   It has really been driven home to me that one size doesn’t fit all when it comes to MOCs.   The regulations are somewhat specific about what should be considered, but this is one of those areas of safety management where the solution needs to fit the problem.

First of all, what are we trying to accomplish with MOCs?   When they work, MOC procedures are a common-sense way to make sure you haven’t missed anything.  You considered:

  • Options
  • Impacts
  • Implementation
  • Responsibility

Yes, there are regulatory requirements for what things need to be considered, but the goal here is to make the best decision, not to be a slave to the regulations, right?

So what are we considering?

Personnel MOCs vs. everything else – The MOC concept first emerged as a way to weigh decisions involving equipment,  operating procedures,materials, and operating conditions – tangible, quantifiable things that can be measured and defined.    The idea of using MOCs to address personnel came later and is a bad fit.    Trying to apply a cookie-cutter MOC policy to both equipment changes and personnel changes is a waste of time.

Levels of complexity – Some decisions take a formal process.   SMEs gather around the table.   Pros and cons are debated.   Decisions that have a long half-life should be thoroughly vetted and everyone should understand the stakes.   For others, it takes a mental discipline.   Did I think through the options and consider the ramifications.  If that little alarm of doubt goes off in my head, I know I need to kick it up to another level.

Field vs. HQ decisions – In truth we make hundreds of MOC decisions in the field that do not require a full review.   The CEO doesn’t need to be involved in deciding whether the crew drinks decaf.  On the other hand, some of the most dangerous decisions a company makes are made in the boardroom or on the engineering design table.   We are back to the difference between occupational safety and organizational safety, which is one of the fundamental balancing acts of any safety management approach.   Field MOCs need to be clear, simple and easy to follow.   They are focused on the here and now and they need to give workers a clear path to know when they need to kick it up to management. Management decisions on the other hand need to anticipate the impact of a decision years down the road.    For example, the field crew needs a process to consider a workaround.  The CEO needs to be involved in a decision to reduce the size of a mentoring program that may help train future leaders.

All of this argues for a flexible MOC approach that focuses on the goal – wise decisions – instead of a slavish process.

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