Module 10 – Managing Change and Influencing Priorities

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 Pre-read

Smith (2012) - Chapter 10

Hopkin (2005) - Disaggregation of NSW Rail (pp.45, 46, 49, 50 62 – 64) (Disaggregation = to
separate into component parts or smaller elements.)

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 Change in the Workplace – two dimensional view
We need to consider two aspects of workplace change and your role in influencing OHS prevention
and management.

◼ In many respects the OHS role is one of being a change agent. You are seeking ongoing
development and improvement in OHS and hence seeking to influence others, and the decisions
that are made, in a positive and preventative direction.

◼ A second aspect is that changes are made to work environments, equipment and processes that
often involve the potential for introducing new hazards and risks that need to be assessed in a
systematic way. This may be a response to both external and internal factors.

In this module we will commence with an overview of an organisational response to the need for
change and how that is tackled from the OHS management perspective.

The final section we will consider the OHS management role and tips for being involved and
influential in the decisions that lead to changes in the workplace.

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 Part One: What Changes
Workplace never remain completely static – there is always
some change and this is necessary to stay competitive

Slow (“creep” “normalisation”) v more rapid v urgent v We are concerned with changes that
temporary
have the potential to
Changes include:
Introduce new hazards
Organisational structure
Personnel Change the level of risk
Cultural
Process
Equipment
Location
Procedures
Knowledge
Regulations

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 Examples of Change
◼ Introduction of new dangerous goods or other ◼ Introduction of temporary processes, buildings,
hazardous materials. plant or equipment

◼ Alteration of the chemical processes. ◼ Changes to the codes and standards applying to
the facility
◼ Increase in the quantity of dangerous goods or
hazardous materials held on-site. ◼ Changes to available knowledge of technical
and operational safety issues.
◼ Addition of new processes, buildings, plant and
equipment. ◼ Changes to the content of management,
operating, maintenance, engineering or
◼ Changes in the design and construction of emergency procedures.
existing processes, buildings, plant and
equipment. ◼ Changes to organisational structure, such as de-
manning, out-sourcing, or relocation of
◼ Changes to the personnel filling safety-critical personnel.
positions.
◼ Changes to contractors or suppliers

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 What is Management of Change (MoC)
A formal process for planning and managing change

SWA (2012) Guide for Major Hazard Facilities Safety Management Systems identifies MoC as
one of the key elements of a SMS

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 Change occurs in all organisations/system

We discuss MoC from major

accident event view point as the
incidents are well known and
understood but MoC applies
across all sectors

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 Case Study – Flixborough Disaster 1974
Before well structured MoC systems were common

https://www.youtube.com/watch?v=WevjRH5fX98

https://www.aiche.org/sites/default/files/docs/em
bedded-pdf/Flixborough-Case-History_0.pdf - read
brief description

Check also …the Dial Before You Dig webpage for

the origins of this scheme in WA! (now Australia
wide)

https://www.1100.com.au/

https://www.1100.com.au/wa/about/

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 Flixborough - MoC
Works Engineer not replaced

Change in workload

No consideration of bending moments or hydraulic thrusts

There was no reference made to vendor manuals

No reference to British Standards

No drawings

No risk assessment

No system for evaluating and controlling changes

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 Esso Longford – Victoria 1998
One of the eleven elements of Esso’s Operations Integrity Management System (OIMS) was
Management of Change

Esso's Management of Change Philosophy

◼ Change is "necessary and desirable“
◼ "changes potentially invalidate prior risk assessments and can create new risks, if not
managed diligently“
◼ “…procedures required any permanent change to an existing facility to be accompanied by
a risk assessment of the change, consistent with the procedures in OIMS Element 2, "Risk
assessment and management".

However, OIMS Element 2 did not identify any procedures for risk assessment associated with
management of change. The only reference to this topic was in the following terms:
"Production Technology operate within a management of change procedure which is
consistent with the EAL management of change philosophy.“”

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 Esso Longford
The Royal Commission dedicated a whole section to MoC
◼ Condensate Transfer from GP1 to GP2 (Longford is actually 3 gas plants – GP1, 2 and 3.
Modification in 1992 – risk assessment process flawed)
◼ Relocation of Plant Engineers from Longford to Melbourne

◼ Changes to Role and Responsibilities of Operators and Supervisors at Longford

◼ Reductions in the Numbers of Maintenance Personnel

Report of the Longford Royal Commission https://www.parliament.vic.gov.au/papers/govpub/VPARL1998-99No61.pdf

See also the analysis by Andrew Hopkins “Lessons from Longford”. (This book is in the Curtin library).

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 Closer to Home - Montara Blowout 2009
This one had world wide attention – Montara
development off NW WA – 250 km offshore from
Truscott and about ½ way between Broome and
Darwin.

The Java Constructor is a large construction barge,

188 POB, 130 m long and uses a 4 point anchor
system.

The barge was not designed to operate where there

was a risk of exposure to hydrocarbons (oil and gas)
(no gas alarms or automated shutdown system, no
zone rated equipment, no temporary refuge, only
push over life rafts, etc).

The JC should have completed it’s work before

drilling commenced but there was a delay getting
the barge to site and so it’s schedule crossed over
with drilling - no effective MoC process was applied.

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 The photo on the left is taken from the port bow of the JC minutes after
the blowout. The JC was anchored 15 m off the platform at the time.

The mist and fluid is condensate (propane, butane, pentane) and other
light oils and the white cloud in the photo is natural gas and LPG (you can
see it as it’s cold and also has some water vapour included).

Had the wind been blowing towards the barge (only about 90 degrees
difference) it’s very likely we would have had a mass casualty situation.

The incident report is scary reading – this was so close it was simply sheer
luck.

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 NOPSEMA MoC Alert
In a 2016 industry alert NOPSEMA raised concerns about poor MoC identified on environmental
plan inspections

“In most cases, NOPSEMA inspectors found that titleholders manage change through partial or
simplistic environmental assessments that are different to the assessments completed for the
submission of the environment plan. Critically, MoC procedures do not consider the change in
the context of the demonstration of impacts and risks to levels that are acceptable and as low
as reasonably practicable (ALARP) in the environment plan in force. Furthermore, they do not
consider changes that may alter the basis upon which the environment plan was accepted.”

“NOPSEMA is particularly concerned about inadequate or poorly applied MoC procedures

which fail to continually identify and reduce environmental impacts and risks to levels that are
ALARP.” https://www.nopsema.gov.au/assets/Environment-alerts/A470472.pdf

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 Step 1 Getting organised
Have a strong policy
Make senior-level managers accountable
Have a clear change-management procedure
Communicate and include everyone
Review and challenge

Step 2 Risk assessment

Identify the people involved
Identify all changes
Assess the risks
Consider human factors, competence and workload
Test scenarios

Step 3 Implementing and monitoring

Provide enough resources to make the change safely
Monitor risks during change
Keep your plan under review, track actions Adapted from: HSE (2003) Organisational
Monitor performance after change change and major accident hazards
Review your change policy http://www.hse.gov.uk/pubns/chis7.pdf

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 The Process
1. Recognition of change situations

2. Evaluation of hazards and risk

3. Decision on whether to allow a change to be made, and

4. Risk control and follow-up measures

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 Questions to ask
Has the hazard been eliminated or the risk reduced to ALARP?

Have any new hazards been introduced?

Is the change necessary, or can an alternative be found that does not introduce new hazards or
does not increase the risk of existing hazards or results in a lesser risk increase?

Is the proposed change in compliance with the applicable regulations, codes and standards?

What measures/systems will be required to ensure continued compliance?

What specifically are the new hazards that are introduced? What is the increase in risk?

What control measures are required?

What changes to the SMS are necessary?

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 Questions to ask
What changes are necessary to notifications, licences or the Safety Case?

What changes are necessary to drawings, procedures and to other documentation?

What are the construction issues for new buildings, plant and equipment?

What are the new maintenance requirements and are there operability issues?

What are the new maintenance eg inspection and test requirements?

Does the holding of spares and consumables need to change?

What additional or changed education and training is necessary?

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 Organisational Change
“Organisational change is a normal and inevitable part of business life in all sectors. But
organisations associated with major accident hazards have a greater potential for disastrous
consequences and higher costs in terms of lives and money. These consequences mean that
organisations managing major hazards must aim for much higher reliability than is normally
necessary in commercial decision making.”

(HSE (2003) http://www.hse.gov.uk/pubns/chis7.pdf )

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 Organisational Change
Business process re-engineering Mergers, de-mergers and acquisitions

Delayering Downsizing

Introduction of ‘self-managed’ teams Changes to key personnel

Multi-skilling Centralisation or dispersion of functions

Outsourcing/contractualisation Changes to communication systems or

reporting relationships.
Joint ventures

Public-private partnerships (PPP’s)

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 Critical Success Factors for Organisational Changes

Require evidence to justify the need for the proposed change and support the proposed
strategy.

Subject proposed changes to a rigorous risk assessment and approvals process.

Include affected members of the workforce in the risk assessment.

Keep affected members of the workforce informed through all stages of the change process.

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 Critical Success Factors for Procedural Changes

Subject proposed changes to a thorough risk assessment, which includes risks relating to
behaviour, not just physical risk.

Involve those members of the workforce who will be impacted by the change in the change
management process, including participation in activities such as drafting, trials, and risk
assessments.

Consider the wider system impacts of the change, including other people or activities that are
seemingly unrelated to the change.

Develop and implement communication plans appropriate to the type and significance of the
change, including training and competency assurance where necessary.
(https://www.nopsema.gov.au/assets/Information-papers/A311536.pdf )

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 Part Two: The Role of the OHS Manager in changing
OHS standards and processes
◼ The issue of promoting and driving change is a significant one for the OH&S manager…

◼ From one standpoint the OHS manager will be seeking to initiate and implement change in
order to advance the OHS system. For many organisations, the OHS system and culture will
be immature, and will need to be adapted with changes in organisational structures and
practices.

◼ The OHS manager also needs to be able to respond to changes in the internal and external
environment.

◼ The pressures for organisations to change, and the difficulties in managing this process, are a
well-known source of stress for employees at all organisational levels. This is potentially an
indirect source of incidents and ill-health.

◼ The OHS change management role must engage with those implementing changes and find a
pace that brings the workforce along with least disruption.

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 Influencing the OHS culture
◼ With rare exceptions, managing the OHS function does not empower OHS personnel to direct
operations, i.e. the line workforce. Direction or supervision is through formal authority, the
organisation’s control structure. OHS is a staff function i.e. it assists, supports, plans, facilitates….

◼ However there is also an informal power structure through which the OHS leader has influence
over decisions.

◼ The informal structure can fill gaps in the formal structure and is particularly useful in times of
rapid change and with new and unexpected situations (eg incident response)

◼ The network of relationships can help in problem solving, provide support for workforce members,
and provide a sense of belonging

◼ Potential negatives may arise from bypassing formal procedures and communications, excessive
rumours or misinformation, and distraction from objectives, unless it is aligned with the formal
management system.

◼ In practice the OHS manager may have significant influence - through expertise in the discipline,
status in the organisation, and the backing of senior leadership

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 Positioning the OHS Management Role
◼ As we have seen, the underlying causes and risk factors for poor health and safety can exist at all
levels, and in all areas and operational activities.

◼ Therefore, in OHS we seek to exert control, or at least influence, with every department, every
function, and all personnel.

◼ There is no fixed reporting path for the OHS management function, this varies for each
organisation, however the following tips may help assess the preferred positioning.
◼ Report to a manager with influence
◼ Report to a manager who wants and supports occupational health and safety
◼ Have a channel to the top (e.g., the CEO, COO, Board, MD, the ‘responsible person’ in WHS law)
◼ Position the OHS lead role with the executive or key manager in charge of the major activity

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 The OHS Manager and Decision Making
◼ Decision making defines the activity of managing and is an everyday part s functions of
planning, organising, leading and controlling.

◼ While decision making is assumed to be a rational process, the unexpected nature of

incidents and the lack of planning function often leads to OHS decisions in a crisis mode.

◼ A systematic approach should involve identification of the problem, an exploration of various

alternatives or options, the making of a decision, and an evaluation of it's effectiveness.

◼ For OHS there is a mandatory requirement to consult with those involved or affected by the
decision making (the workforce). This also leads to decisions that are more likely to be
supported and improve the work process. (NB: the central role of OHS Representatives,
complemented by the OHS Committee)

◼ A special consultation process in the legislation is the need for a resolution of issues process.
This gives all personnel a clear, step by step, process for finding solutions when differences of
opinion arise. This is in effect the heart of the self regulatory and co-determination
philosophy.

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 MoC is an opportunity to improve safety

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 Discussion Points
Why is change so hard to manage?

In many cases internal procedures identify that the “change” should have been reviewed – so
why wasn’t it?

Considering the disaggregation of NSW Rail discussed by Hopkins and what we have discussed
so far on accident models and safety culture - What things might impact the effectiveness of
management of change?

What are the characteristics of an effective and influential OHS leader?

Can OHS be improved without commitment from the top? What would it take?

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 Further Reading
https://www.worksafe.vic.gov.au/__data/assets/pdf_file/0018/211248/ISBN-Management-of-
change-at-major-hazard-facility-2011-03.pdf

https://www.nopsema.gov.au/assets/Information-papers/A311536.pdf

http://www.hse.gov.uk/pubns/chis7.pdf

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