Management of Change: Emergency Change
We continue our discussion to do with Management of Change (MOC). Previous posts in this series are:
Types of Change
If change is to be managed properly, it is necessary to understand the types of change that are typically made on a facility — each will require its own response. Changes can be categorized as follows:
Initiated change;
Non-initiated change;
Temporary change;
Emergency change; and
Administrative and organizational change.
In this post we look at Emergency Change.
Emergency Change
Sometimes it is essential that a change be made very quickly. In these cases, the people wishing to make the change feel that they are justified in taking the necessary action without invoking the full Management of Change process. This type of change is justified when there is the potential for a serious short-term impact in areas such as the following:
Danger to personnel;
Major equipment damage;
Major operational loss;
Serious environmental loss;
Community complaint; or
Regulatory violation.
Generally, the justification for an emergency change is that a person in line authority — a shift superintendent for example — decides that the dangers associated with doing nothing are greater than those associated with the proposed change, even though that change has not been properly evaluated or authorized. Time is of the essence.
Using the leaking pump seal example once more, the warehouse superintendent may report that he does not have identical seals with which to replace the leaking item, but they do have others which are very similar. In this situation, the operations and maintenance supervisors may decide to make the change right away using the incorrect seal, even though they know that it is not a true In-Kind replacement. They decide that the risk associated with using a similar, but not identical, seal is less than that of the leaking vapors catching fire.
In spite of the fact the emergency changes bypass the full, formal MOC process it is important to have at least one review of the proposed change. There may not be time to assemble a full MOC team; nevertheless, the change ought to be reviewed by at least three people. These people should represent different disciplines or departments, and should operate in the same way as the normal review team, i.e., they should systematically investigate the nature and consequences of the proposed change — probably using an abbreviated What-If approach. Only in a true life-or-death situation, where seconds or minutes count, can a single person assume full responsibility for making a change without having a team review first.
Every effort must be made to minimize the number of emergency changes because they bypass the normal systems for checking for hazards. This is why all employees should be thoroughly trained in the use of the formal system. Once it becomes familiar to them, and once they understand its importance, they will be less inclined to bypass it. Moreover, those who are familiar with the formal MOC process will tend to follow its precepts, even when they are in a hurry.
Following its implementation, an emergency change should be validated by a normal MOC review in order to make sure that no problems have been overlooked. Even if the emergency change can be shown to be safe in the long-term, a full evaluation of what occurred may show that the action taken was not optimal. A more efficient or practical solution to the problem may be uncovered.
