Some of our readers, especially those with existing Job Hazard Analysis/Job Safety Analysis programs (OSHA), Risk Management Programs (EPA), or ISO certification, already have management of change integrated into these programs. However, for those who currently are handling change more like, “ready, fire, aim…”, let me share what one of our chemical clients does to assure effective management of change.

The first step is realizing that no single individual has the total perspective on the many impacts a pending change may have, even if you are the one who gave birth to the company or process. One person’s viewpoint and experience will be different than yours…not right or wrong…but, almost always, different. So, despite the wise advice to keep it simple, a committee of people (with their functional expertise and departmental interest at heart) will be needed for the best chance to spot potential problems before they arise during implementation. For our chemical client, that included:

  • Purchasing – Do I need new sources? What supply chain problems may arise? What safety data sheet, handling, transport or disposal problems may result?
  • HR – Do we have the needed expertise and staffing? What training requirements are involved with the new process/products/ raw materials?
  • EHS – What environmental, safety and transport regulations come into play? Do we need new written programs, safety training, different PPE? What additional reporting and data capture will be needed?
  • Maintenance – What is unique about the new equipment that may pose safety, maintenance, or replacement parts issues? Do we have adequate access allowed for repairs and routine maintenance? What training is needed?
  • Finance (and the outside banker or insurance agent) – What are the impacts on inventory levels, P&L statement, additional risk (insurance premiums and worker’s comp)?
  • Production – What are the new demands for production time and resources? Do we have the properly trained workers and supervision? What new safety procedures and PPE will be needed and who provides that training? Can we get it all done? What other expenditures for facility changes or associated equipment might be needed?
  • Other “service providers” – input was welcomed from “internal service providers” like Customer Service, Scheduling, Accounting, IT Dept. and Warehousing, as needed to check for unforeseen details/concerns.

This list of questions is not all-inclusive and varies by the nature of the product/process under consideration. Taken to extremes, it certainly sounds like a lot to consider and could lead to “paralysis by analysis” with unacceptable lead-times needed for even the simplest changes. Yet, for our chemical client, it works very well and minimizes any unwanted surprises during implementation. Most notably, they have honed the Management of Change to where the whole approval process takes 24-48 hours before they determine if a custom-blended new product or new process can be undertaken. It’s time well-spent and highly recommended… even if you are currently wearing most of these hats yourself and are charged with just “making the changes happen”. For you, “no surprises” can be a welcomed change!

Published by Glenn Miller

Senior Compliance Manager Mr. Miller provides a broad range of consulting services to CTI’s clients based on over 30 years of experience in the chemical industry. Along with helping to coordinate CTI’s diverse consulting projects and assisting in CTI’s marketing efforts, he specializes in HazCom programs, dangerous goods handling and labeling (GHS, HMIS and NFPA), transportation compliance (DOT/IATA and IMDG), site audits, global regulatory compliance (REACH, TSCA), Process Safety Management, and training. You may direct questions to our Senior Compliance Manager, Glenn Miller, at 216.341.1800, ext. 14

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