Help with Board Question no word count, and assessment questions. APA Format throughout including reference page. 

Board Question

Share with the class any experiences you have with process improvement methodologies such as lean, Six Sigma, total quality management, or others. Did you find it an effective process? How could it be improved? If you have no experience with process improvement, discuss how lean concepts could be incorporated where you work or used to work.

Unit Assessment

QUESTION 1

A manufacturing facility that makes steel materials handling devices such as hand carts and an assortment of roller carts for moving heavy materials around in manufacturing facilities has decided to start making cantilever storage racking systems. This will require the purchase and installation of a 12-foot hydraulic press brake and a 12-foot shear in the fabrication department along with the necessary tools and dies to bend and punch holes in the rack components that will largely be manufactured from formed sheet metal. Employees have experience working smaller versions of this type of equipment, but room will need to be made and larger pieces of sheet metal will need to be cut and handled. The department will also need to continue to produce existing orders while the new equipment is installed. How can a management of change program be used to reduce risks in such a scenario?
Your response must be at least 75 words in length.

QUESTION 2
Your organization, a company that manufactures fitness equipment such as treadmills and elliptical machines, is about to introduce lean concepts into its operations in order to be more competitive with foreign manufacturers. The foreman from the assembly department, however, does not think that his employees have the time to be involved with the lean initiative. Provide a convincing argument about why it is important for the assembly line workers to play a part.
Your response must be at least 75 words in length.
QUESTION 3
Your purchasing department does not want to buy adjustable hydraulic pallet stands for the filter assembly line at a company that makes oil filters for cars and trucks. They state that the current process works just fine and that expensive, adjustable stands are not required in the Occupational Health and Safety Administration standards. The production employees in the facility are largely female and many have worked at the facility for decades. The current process for accessing filter parts entails having assemblers bend over to pick up arm loads of the various filter components from a pallet or bin and placing them on a table beside their respective workstations. The parts are assembled and pressed into place, and the completed product placed in a separate bin. Please provide a risk-based argument as to why the adjustable pallet stands would be the better choice.
Your response must be at least 200 words in length.

1

Course Learning Outcomes for Unit VII

Upon completion of this unit, students should be able to:

6. Relate continuous improvement principles to safety management concepts.
6.1 Detail the link between lean concepts and the safety management system.

7. Examine management tools necessary to implement effective safety management systems.
7.1 Explain how a management of change process can reduce serious injury potential.
7.2 Illustrate how safety design reviews can reduce risks introduced by procurement processes.

Reading Assignment

Chapter 18:
Lean Concepts—Emphasizing the Design Process: Section 5.1.3 of Z10

Chapter 19:
Management of Change: Section 5.1.3 of Z10

Chapter 20:
The Procurement Process: Section 5.1.4 of Z10

Unit Lesson

Business owners and managers are always looking for the best way to run their operations to maximize
profits. Many new management systems and processes have been developed and implemented with varying
degrees of success in recent years. Regardless of what management system an organization uses, it is
critical for safety processes to be integrated into the larger structure of the organization. That is to say, the
safety and health management system should not stand alone from the other management efforts put forth by
the management of the facility. Integration of the safety and health program with other management systems,
rather, is key to successful implementation.

A management concept that has proven successful for many organizations (particularly in the manufacturing
sector) is lean management, used successfully for more than 50 years by the Toyota Corporation. The basic
premise of lean is to reduce waste in all phases of an operation (Manuele, 2014). What better example of a
waste of valuable resources is there than an injury or illness? Recall that the hierarchy of controls tells us the
best place to reduce risk is at the design stage of a product or process. It is also at the design phase that lean
concepts can be applied for the greatest benefit. Z10 does not specifically address lean, but it does call for
processes that prevent or stop hazards at the design and redesign phases (Manuele, 2014).

One of the foundations of lean is the 5S concept (Manuele, 2014).

 Sorting, where everything not needed is removed from the workplace;

 Simplifying, where everything needed has a place and is well marked;

 Systematic cleaning, where orderliness is created and maintained;

 Standardization, where best practices are developed and adopted for efficiency; and

 Sustaining, where the previous steps are maintained.

Anvari, Zulkifli, and Yussuff (2010) propose that a sixth S, for safety, be added between systematic cleaning
and standardization, and they found that some organizations have already done so. They feel this gives safety
the visibility and integration it deserves as a significant contributor to reduction of waste. Manuele (2014)

UNIT VII STUDY GUIDE

Integrating Safety Management and
Operational Management

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UNIT x STUDY GUIDE

Title

warns that representing safety in its own step might signal that safety is not really integrated but still separate.
The U.S. Environmental Protection Agency (EPA) has adopted a 6S model that shows safety as surrounding
all the other steps. Organizations must decide what is best for them, and however lean is implemented, it is
important for the safety staff to have an active role in the process. Also, as mentioned above, it is important to
assure that lean safety initiatives such as 5S (or 6S) are well integrated into the overall management systems.

In contrast to the tenets of the 5S (or 6S) system mentioned above, envision a small manufacturing facility
that utilizes forklifts but has unmarked aisles. Metal fabrication dies and punches are stored on shelves in no
particular order, and the only way to know if one is damaged if it is not obvious is to ask Bubba the
mechanical press operator. Metal banding can be spotted in walkways. Palletized materials are stored in front
of exits and electrical boxes. Flammable liquid storage cabinets used to hold toluene and xylenes are left
open 24 hours a day, and there is a radio sitting on one plugged into an adjacent extension cord which runs
through a hole in the wall and is plugged in somewhere on the other side. There are also racks of dusty
unused parts from previously discontinued products that did not sell. The key point here is that thoughtful
organization is important when it comes to injury prevention efforts. In this scenario, we have everything from
fire, tripping, and electrical hazards to potential projectile hazards from exploding punches. The bottom line is
that keeping things in an orderly manner is a good policy when it comes to accident prevention in the
worlplace.

Have you ever heard the adage “Nothing is constant except change?” In some organizations, it does seem
true: reorganizations, rebranding, reorganizations, new products, reorganizations, mergers, and acquisitions.
Did I mention reorganizations? Many books have been written, and many consultants are waiting to guide
organizations through the maze of these transformations. In his research into serious injuries and fatalities,
Manuele (2014) found that a large proportion of incidents resulting in severe injury occur in unusual and non-
routine work, during modification or construction operations, during shutdowns for repairs, during maintenance
and startups, and when situations go from normal to abnormal, in other words, when things change. It is no
surprise, then, that an entire chapter in the course textbook, Chapter 19, and a section of Z10 deal with
management of change.

Many organizations have great safe operating procedures, job hazard analyses, and other safe work systems
in use. How many, however, have a plan on how to deal with changes in processes, equipment, procedures,
or personnel that may alter the risks previously identified? One place where one is likely to run across a
management of change program, as was mentioned in a previous unit lesson, is the Occupational Safety and
Health Administration (OSHA) Process Safety Management standard which covers employers that process
and store dangerous quantities of highly hazardous materials. According to OSHA (2000):

Changes to a process must be thoroughly evaluated to fully assess their impact on employee safety and
health and to determine needed changes to operating procedures. To this end, the standard contains a
section on procedures for managing changes to processes. Written procedures to manage changes
(except for “replacements in kind”) to process chemicals, technology, equipment, and procedures, and
change to facilities that affect a covered process, must be established and implemented. These written
procedures must ensure that the following considerations are addressed prior to any change:

 The technical basis for the proposed change,

 Impact of the change on employee safety and health,

 Modifications to operating procedures,

 Necessary time period for the change, and

 Authorization requirements for the proposed change.

Employees who operate a process and maintenance and contract employees whose job tasks will be
affected by a change in the process must be informed of, and trained in, the change prior to startup of the
process or startup of the affected part of the process. If a change covered by these procedures results in
a change in the required process safety information, such information also must be updated accordingly.
If a change covered by these procedures changes the required operating procedures or practices, they
also must be updated. (para. 1-3)

It should be clear by applying common sense that this is a wise approach to take when dealing with highly
hazardous substances; however, such an approach is not necessarily limited to companies that are required
to comply with the PSM Standard. If you think about it, management of change is in alignment with the PDCA

3

UNIT x STUDY GUIDE
Title

cycle philosophy, particularly with respect to the Check and Do phases of the cycle as well as section 6.0 of
Z10. Uitlizing such a management tool is clearly useful in helping to address difficult-to-spot hazards resulting
from signficant changes in organizational processes. Remember, we want to prevent injuries and illnesses.
Why not introduce a process that anticipates problems that might occur as a result of organizational and
facility changes earlier rather than waiting for an incident to happen? That is management of change, and it is
part of the Do phase and section 5.0 of Z10. Manuele (2014) suggests that for management of change to be
effective, it must be a formalized process. Many good examples can be found in safety literature.

Closely related to safety design reviews, reviewing procurement specifications allows the safety professional
to reduce risk up front by ensuring risks are identified and addressed. Influencing the procurement process
may well be one of the most difficult challenges for the safety professional. This is particularly true when the
price of an expensive piece of equipment is considered. Once again, Manuele (2014) looks to ergonomics as
a way to get a foot in the door, and just like the design review process, it is important to keep the dollar sign
savings in front of management. Consider a situation, for example, where stands that hold raw material to be
stamped by a press operator are considered that can be adjusted to the height of the worker but that will cost
$47,000 more than non-adjustable stands. It will not take too many costly back injuries to add up to $47,000.
As mentioned in a previous unit lesson, speaking the language of business can be quite useful when it comes
to advocating safety in the workplace, and it can be used for advocating important safety and health related
efforts such as lean-safety-related initiatives and management of change.

Course Project

As in previous units, the non-graded learning activities in this unit contain an exercise designed to help you
with the course project that will be due in Unit VIII. By completing this activity and similar ones in other units,
you will have most of the data and analysis needed to put together a high-quality report to management on
the state of the safety management program.

References

Anvari, A., Zulkifli, N., & Yussuff, R. M. (2011). Evaluation of approaches to safety in lean manufacturing and
safety management systems and clarification of the relationship between them. World Applied
Sciences Journal, 15(1), 19-26.

Manuele, F. A. (2014). Advanced safety management: Focusing on Z10 and serious injury prevention (2nd
ed.). Hoboken, NJ: Wiley.

Occupational Safety and Health Administration. (2000). Process Safety Management. OSHA 3132. Retrieved
from https://www.osha.gov/Publications/osha3132.html#moc

U.S. Environmental Protection Agency. (2011). 6S (5S+safety). Lean and environment toolkit (pp. 49-60).
Retrieved from
http://www.epa.gov/lean/environment/toolkits/environment/resources/LeanEnviroToolkit

Suggested Reading

In order to access the following resource, click the link below.

The suggested reading below provides additional content on lean management and safety:

Hansen, M. D., & Gammel, G. W. (2008). Management of change. Professional Safety, 53(10), 41–50.
Retrieved from
https://libraryresources.waldorf.edu/login?auth=CAS&url=http://search.ebscohost.com/login.aspx?dire
ct=true&db=bth&AN=34751716&site=ehost-live&scope=site

https://libraryresources.waldorf.edu/login?auth=CAS&url=http://search.ebscohost.com/login.aspx?direct=true&db=bth&AN=34751716&site=ehost-live&scope=site

https://libraryresources.waldorf.edu/login?auth=CAS&url=http://search.ebscohost.com/login.aspx?direct=true&db=bth&AN=34751716&site=ehost-live&scope=site

4

UNIT x STUDY GUIDE
Title

Learning Activities (Non-Graded)

Non-graded Learning Activities are provided to aid students in their course of study. You do not have to
submit them. If you have questions, contact your instructor for further guidance and information.

Management of Change

Review the types of safe work documents in use at your organization (Standard Operating Procedures, Job
Hazards Analyses, etc.). What types of changes might make these documents less effective? Consider things
such as weather, new tools, product changes, new personnel, and revised deadlines. Develop a policy that
would require review of safe work documents in specific circumstances.

Evaluating Operational Elements of the Safety Management System

Note: This activity can be used as one of the building blocks of the Unit VIII Project.

Using Chapters 18, 19, and 20 of the course textbook as guides, evaluate safety design reviews,
management of change, and the procurement process at your current organization or an organization with
which you are familiar. For objective evidence to support your evaluation, look for organizational documents
such as safety manuals and instructions, safe operating procedures, and job hazard analyses and records
such as emails or letters from management to employees, safety meeting minutes, mishap logs, audit reports,
Occupational Safety and Health Administration citations, inspection reports, risk assessments, and training
records. Interview management personnel, supervisors, and employees, and walk through some workplaces
to observe conditions for yourself. Prepare a report to management that summarizes the positive and
negative results of the evaluation and provides recommendations for improvement.

CHAPTER 20

THE PROCUREMENT PROCESS:
SECTION 5.1.4 OF 210

Although the requirements in ZIO for the procurement processes are plainly stated
and easily understood, they are brief in relation to the enormity of what will be
required to implement them. Little”help is given as to utilization of the procure-
ment provisions. Advisory notes are brief. Documenting the procurement process
is the subject of E5. l.4. Appendix I is a one-page informative description of the
procurement process. •

As is the case for the provisions in ZIO on safety design reviews, the purpose of
Procurement processes is to avoid bringing hazards and their accompanying risks

into the workplace. The standard reguires that processes be instituted so that reviews
~ade of products, materials, and other goods purchased and related services to

ide~l!fy and evaluate health and safety risks before their introduction into the work
~
0
VJronment. To fulfill the procurement provisions, safety specifications must be included· h

In pure ase orders and contracts.
in thisT? assi

st
safety professionals as they give advice on implementing those provisions,

chapter we:

• Conunent briefly on prevalent purchasing practices
• Establi b
• . s the significance of the procurement processes

Discuss the pre-work necessary to include safety specifications in the procure-
lllent Process

• Provide some resources

Sctond F.di/ery t;1anagemem: Focusing 011 ZJO and Suious llljury Prevention .
O 2014 John on. red A. Manuele.

W-t1ey & Sons, Inc . Published 2014 by John Wiley & Sons, Inc.

399

400 11-lE PROCUREMENT PROCESS: SECTION 5.1.4 OF 210

• Comment on the paucity of publicly available occupational health and s r
. ‘ti . a,ety

purchasing spec1 cattons
• Remark on the need, sometimes, to set specifications above published standards
• Give examples of design specifications that become purchasing specifications

THE REAL WORLD OF PURCHASING PRACTICES

Unfortunately, the practice in many companies in the bid process for acquiring
machinery, equipment, and materials is that purchasing departments are to choose
the lowest-qualified bidder. For many years, safety professionals have told stories
about how purchasing personnel have accepted the lowest bid on safety-related
products or material~ only to find, after their receipt, that they did no,t fulfill opera-
tional expectations and that safety needs were not met. Expensive retrofitting for
safety purposes was necessary. ·

Retrofitting to accommodate safety needs starts with evaluating the deficiencies
in the equipment as it is in operation: that is, identifying what was overlooked in the
design process. Unfortunately, the resulting level of risk when safety requirements
are addressed through retrofitting may be higher than would be the case if safety
specifications were included in the bid or purcq,asing papers. As retrofitting proceeds,
it’s easy for decision makers to rationalize acceptance of higher risk levels.
Nevertheless, the goal should be to achieve acceptable risk levels.

Getting managements and purchasing personnel to adopt the procurement
provisions in z19 will not .be easy. A safety profes.sional who proposes adding
procurement provisions as an element in safety and health management systems
and to have safety specifications included in a company’s purchasing practices
should expect the typical resistance to change: I.n most places, a culture change
will be necessary for success.

An oblique interpretation of the procurement requirements could be: Safety and
health professionals, you are assigped the responsibility to convince managements
and purchasing agents that, in the long term, it can be very expensive to buy cheap.

‘ SIGNIFICANCE OF THE PROCUREMENT PROVISIONS

I place great emphasis on having the procurement provisions in Z 10 becoming_ an el::
in safety and health management systems because doing so prevents introducmg h
and risks into a workplace. This is the thinking that supports that position.

Risks of injury derive from hazards. If hazards are properly addressed and
avoided, eliminate, reduced or brought under control in the design process t
that the risks deriving from them are at an acceptable level, the •potential or
harm or damage and operational waste are minimized. 5

Thl ·1. f . d·nproces e og1ca extension o address mg hazards and risks in the esig d • n
is to have the design specifications the organization decides upon inclu~:fe;Y
purchase orders and contracts so that suppliers and vendors know what

RESOURCES 401

•jjcations are to be met. That reduces the probability of bringing hazards
~pecithe workplace. into

Jthough having safety specifications included in purchase orders or contracts is
A ractice applied broadly, safety professionals are encouraged to consider the

not
8
6~ to be achieved if they are. If the ideal is attained in the purchasing process and

be~ and risks brought into the workplace are as low as reasonably practicable, the
h ult is significant risk reduction, which means fewer injuries.
res UnfortUnately, the only safety-related terminology in purchase orders and contracts
roay be to meet all OSHA and other governmental requirements.

PRE-WORK NECESSARY FOR PROCUREMENT APPLICATIONS

As we say in Chapter 15, “Safety Design Reviews,” there is a close relationship
between establishing safety design specific!ltions and including safety specifications
in procurement documents. The latter cannot be achieved successfully until the
former bas been accomplished. .

Once safety design specifications are established, the next step is to have them
applied internally. Then, an appropriate extension is to have them incorporated into
purchase orders and in contracts.

It is common practice for vendors and suppliers of equipment to use their own,
and possibly inadequate, $afety specifications if a purchaser has not established its
requirements. That could end up being costly for the purchaser, especially if produc-
tion schedules are delayed and the retrofitting expense to get systems operating as
designed and for safety purposes is substantial.

RESOURCES

In Annex E, “Objectives/Implementation Plans,” the following appears under
Objectives for the Procurement provision: Distribute’ approved policy; Train on
~!icy and procurement procedure; and Distribute safety requirements to be included
ID Standard co’ntracts. (p. 44) ‘

That presumes that a procurement policy and safety requirements have been
e51ablished and distributed and that training on their implementation is to be given.
Procedurally, that’s ‘ a ,good and recommended practice. Procurement is listed in
Appendix_ L, ”Audit;’ as one of the subjects to be reviewed when a safety audit is
:~e. This audit guide says that in the audit process, the following are to be consid-

as aspects of the procurement section in the standard. ·

Documents to Be Reviewed
• Procedures for selection, evaluation, and management

Reco,ds to Be Reviewed .
‘ Selected 1· supp 1er self-assessments
• Selected supplier audits and ratings

402 THE PROCUREMENT PROCESS: SECTION 5.1.4 OF 210

• Selected supplier contracts
• Incoming product inspection records
• Product risk analyses

Interviewee
• Selected ~upplier management personnel
• Hourly employees

Observations
• Selected purchased products to check associated procurement records

Although the foregoing provides-somei guidance, what is proposed lacks the most
important element in a procurement process, which is to establish the specifications that
suppliers are expected to meet. Section 5, “Relationships with Suppliers,” in ANSI/
ASSE Z590.3, Prevention Through Design: Guidelines for Addressing Occupational
Hazards and Risks in Design and Redesign Processes, is informative with respect to the
procurement provisions in Z 10. For one example: the standard says that in relationships
with suppliers, “top management shall establish and document its occupational hazard
and risk specifications.”

THE PAUCITY OF AVAILABLE HEALTH AND SAFETY ·
PURCHASING SPECIFICATIONS

Several safety-related texts were reviewed to determine whether they give guidance
on including safety specifications in the procurement process. They do not. Examples
of some safety-related purchasing specifications posted on the Internet follow._There
are others.

• University of California, Environmental, Health. and Safety (EH&S) Laboratory
Safety De!)ign Guide, 2nd edition. At http://us.yhs4.search.yahoo.cqm/yhs/
search?p=University+of+Califomia%2C+Environmental%2C+Health+and+Sa
fety+%28EH%26S%29+Laboratory+Safety+Design+Guide&hspart=att&hsim
p=yhs-att_OOl&type=att_lego_portal_home

• Queen’s University Environmental Health and Safety: Laboratory Flammable
and Combustible Liquid Handling Procedures. At http://us.yhs4.search.yahoo:
com/yhs/search;-ylt=A0oG7oNbrlhR.ysAu14PxQt.?p=%E2%80%A2%09Uru
versity+of+Califomia%2C+Environmental%2C+Health+and+Safety+%28EH
%26S%29+Laboratory+Safety+Design+Guide&type=att_lego_portal_home
&hsimp=yhs-att_OO 1 &hspart=att&pstart= 1 &b= 11

• Duke University, Summary of Class 4 Laser Laboratory Design Guidance, at www.
safety.duke.edu/RadSafety/laser-lab-design

• Yale University’s Procedure 3220, “Purchases of Restricted Items,” among
which are:

OPPORTUNITIES IN ERGONOMICS 403

• yazardous materials: Materials that present special safety risks during trans-
pcrt, stora~e, use,_ or disposal. :niese include, but are not limited to, certain
highly toXIC, reactive, or otherwise hazardous chemicals, gases, and biological
agents.

• safety-Critical Equipment: Equipment that can present safety hazards to users
(e.g., x-ray and laser equipment) as well as equipment used to control exposures
to recognized hazards, and whose improper use could subject users to harm
(e.g., fume hoods, biological safety cabinets, respirators, automated film pro-
cessors). At http://us.yhs4.search.yahoo.com/yhs/search?p=%E2%80%A2%09
Yale+ University %E2 %80%99s+ Procedure+ 3 220+&hspart=att&hsimp=
yhs-att_OOl &type=att_lego_portal_home

• University of Wollongong, New South Wales, Australia. WHS Purchasing
Guidelines (WHS, Workplace Health and Safety). Available at http://us.yhs4.
search.yahoo.com/yhs/search?p=HRD-WHS•GUI-070.9+WHS+Purchasing+
Guidelines+ 2013+&hspart=att&hsimp=yhs-att_ 001 &type=att_lego _portal_
home. (The Guidelines are an ·addendum to this chapter.)

• Toe Bedfordshire Community Safety Guide. At http://www.bedfoi:’d.gov.uk/
environment_and_planning/planning_town_and_country/what_is_plarining-
policy/ documents_of_the_bdf/bedfordshire_community _safety.aspx

It is interesting that the first five entities in the list above are universities, and the
last is a municipality. Since they are governmental entities, the materials they pro-
duce are almost always in the public domain.

Examples of applications of safety-related design standards that become purchasing
specifications are not easily acquired. Most companies consider their specifications
proprietary and don’t make them available to others freely. For a moderate-sized
company with a limited engineering staff, writing design·and purchasing specifications
will not be easy to do.

It seems appropriate to suggest that organizations prevail on the business associ-
atians of which they are members to undertake writing generic design specifications
and purchasing specifications that relate to the hazards and risks inherent in their
operations. Safety professionals should consider this inadequacy as an opportunity
to be of service and make their presence felt.

However, arrangements were made for an additional example of internal design
specifications that are also purchasing specifications to be included as an addendum
to this chapter.

OPPORTUNITIES IN ERGONOMICS

As is the case with ZlO’s safety design review provisions, safety professionals who
are ~ot involved in the design or purchasing processes should consider ergonomics as
:ertile ground in which to get started. Some of the comments made in Chapter 15,
/a_fety Design Reviews,” are repeated here because they apply equally to ZlO’s
esign and procurement provisions.

fi 404 lliE PROCUREMENT PROCESS: SECTION 5.1.4 OF 210 Musculoskeletal injuries, ergonomically related, are a large segment of the spectrum of injuries and illnesses in all industries and businesses. Since they are costly, reducing
their frequency and severity will show notable results. Furthermore, it is well established
that successful ergonomics applications result not only in risk reduction, but also in
improved productivity, lower costs, and waste reduction.

Ergonomists know how to write design specifications for ‘the workplace and the
work methods that take into consideration the capabilities and limitations of workers. A
company that established detailed ergonomics design criteria to be followed by its own
engineers and by its vendors and suppliers was DaimlerChrysler. The following intro-
duction to the DaimlerChrysler ergonomic design criteria demonstrates the relationship
between writing design specifications and including them in purchasing requirements.

This document attempts to integrate new technology around the human infra-
structure by providing uniform ergonomic design criteria for DaimlerChrysler’s
manufacturing, assembly, power train -and components operations, as well as
part distribution centers. These criteria supply distinct specifications for the
Corporation, to be use4, by all DaimlerChrysler eng.\neers, designers, builders,
vendors, suppliers, contractors etc. providing new or refurbished/rebuilt mate-
rials, services, tools, processes, facilities, task designs, packaging and product
components to DairnlerChrysler.

In effect, the ergonomic design criteria to be used intemally ,at DaimlerChrysler
also became the ergonomic specifications that vendors and suppliers had to meet. In
a section on supplier roles and responsibilities, it . is made clear that all suppliers
were to “make all reasonable efforts to implement all of the criteria and requirements”
of the ergonomic design criteria. If a design requirement was to be compromised, the
supplier had to so inform DaimlerChrysler and the matter would be reviewed to a
conclusion by a DaimlerChrysler ergonomics representative.

DaimlerChrysler’s e~onomic design criteria are available at http://www stoc.
com/docs/25321410/150-ergonomic-design-criteria. The criteria may be downloaded
for personal use or business use.

GENERAL DESIGN AND PURCHASING GUIDELINES

Addendu~ A to this chap~er is a combination of design and purchasing guidelines
currentlr m use: Not~ agam that design specifications were developed that became
purchasing spec1ficauons. The document is presented here as a reference from which
engineering personnel and safety professionals can make selections and add subtract,
or _alte_r item~ to suit location n_eeds. It would be inappropriate to implen:ent these
gm~elmes w1_thout study and adJustment to reflect the hazards and risks inherent in a
particular enuty .
. Ado~tion. of a modific~tion of the guidelines will usually require persuasive

di~cus~10n w11h_ the p~rchasmg staff. Getting a procurement process as outlined in the
gu1delmes applied will require a culture change in all but a few organizations. Safety

oes1GNI N
G AND WRITING SAFElY SPECIFICATIONS BEYOND THE LEVEL OF STANDARDS 405

r 1·onals must understand the enonnity of what is b~ing undertaken when they pro1ess ‘fi . . 1 d d . bave safety spec1 cations me u e m purchasing documents when that is not
trY tourrent practice. Nevertheless, the productivity, risk reduction, and waste-saving
tbe c th ‘d b · · h t,enefits of a process at av01 s nngmg azards and risks into the workplace cannot
be refuted. . . . . . .

The Guidelines begm with sections on general safety requirements, machine
arding, industrial hygiene, ergonomics, machine and process controls, and

g\ironrnental impact/hazard evaluation. Section 8 sets forth a procedure for which
en · “U thi d the instrUction 1s: se s ocument as a guide whenever purchasing new
(or modifying exis~ng) e~uipment.’:

Major parts of this section deal with codes and Standards, equipment/fixture design;
mechanical design and construction, electrical design and construction, pneumatics
design and construction, software, and machine guarding. ·

These guidelines are quite broad. They relate to occupational safety and health,
environmental concerns;· productivity and avoiding events that result in business
interruption.

DESIGNING AND ·WRITING SAFETY-SPECIFICATIONS
BEYOND THE LEVEL OF STANDARDS

In the safety standards writing process, it is common for contributions to be made by
many participants, and compromises are made in the deliberations to accommodate
the variety of views expressed on the subject being considered. The result often is a
standard that includes minimum requirements. The following appears. In Chapter 12:
Provisions for Risk Assessments in Standards and Guidelines.

A supplementary and advisory document to SEMI S2 (Environmental, Health,
and Safety Guideline for Semiconductor Manufacturing Equipment) is titled
Related Information I – Equipment/Product Safety Program. It makes an inter-
esting statement, cited below, about the need, sometimes, to go beyond issued
safety standards in the design [and purchasing] process.

Compliance with design-based safety standards does not nece~sarily ensure
adequate safety in complex or state-of-the-art sys

1
tems. It often is necessary to

perform hazard analyses to identify hazards that are specific with the, system,
and develop hazard control measures .that adequately control the associated
risk beyond those that are covered in existing design-based standards.

1\vo subjects COJlle to mind that encourage designing beyond compliance standards.
Systems designed in accord with OSHA’s lockout/tagout and confined space standards
may be error-provocative.

‘ Assume that an electrical system is designed to OSHA lockout/tagout require-
ments and to the requirements of the National Electrical Code but that the distance
workers have to travel to lockout stations is, in their view, too far and burdensome.

I

406 THE PROCUREMENT PROCESS: SECTION s.1. 4 OF 210

I . …n: t ‘that sometimes workers will not follow the·written standard t IS a near ce~ uun y · .
ti. eci””es If the system’s·design and the purchasmg contract merely opera ng proc ….. . . ,

say “Meet OSHA requirements,” the •result could be an error-provocative sy~tem.
S · · ·hasi·ng (construction) contracts that confined spaces should be • aymg m pure . . .
designed to meet OSHA’s standard may also result ~n creating error-provocative
situations. An appropriate goal is, first, to to des1~n out confin~ spaces, and
then consider the safety entry and exit needs m the·des1gn process where confined
spaces must exist. · · ·

CONCLUSION

Too much stress cannot be placed on the significance of the procurement provisions in
Zl O and the benefits that will derive from their impleme.ntation. It stands to reason
that if the purchasing process limits bringing hazards and risks into the workplace, the
probability of incidents resulting in injury or illness will be diminished. That’s what
210 is all about: ”To reduce the risk of occupational injuries, illnesses, and fatalities.”

Since very few organizations have processes in place that comply with ZlO’s
procurement provisions, safety professionals a:re faced with:an enormous task as they
attempt to convince managements to adopt: those provi&ions. Surely,. undertaking
to do so is a worthy and noble task. Although Addendum A to this chapter is lengthy,
it is recommended that safety professionals read it to gain an· appreciation of how
extensive design and purchasing specifications can be and how they can serve well to
avoid bringing hazards and risks into,th~ . .workplace. Also, it must be understood that
design -engineers may not agree with some.of the specifics included in the guidelines
and would write different safety-related specifications. .

Addendum B is a find. It is brief but is included because of the entity that issued it.
The purchasing guidelines developed at the University of Wollongong are an excellent
resource and highly recommended.

REFERENCES

ANSYAIHA 210-2012. American National Standard, Occupational Health and Safety
Management Systems. Fairfax, VA: American Industrial Hygiene Association, 2012. ASSE
is now the secretariat: Available at https://www.asse.org/cartpage.php?link=i10_2005.

ANSYASSEZ590.3-2011. Prevention Through Design: Guidelines for Addressing Occupational
Hawrds and Risks in Design and Redesign Processes. Des Plaines, -IL: American Society of
Safety Engineers, 2011.

Ergonomic Design Criteria. DaimlerChrysler. http://www stoc.com/docs/25321410/
150-Ergonomic-Design-Criteria.

OSHA. Summary of ~SHA Permit-Required Confined Spaces Rule. The rule citation is 29
CPR 1910.146. Avadable at http://www.dol.gov/elaws/osha/confined/PRCSGEN.asp.

OSHA. General Environmental Controls. Standard Number 1910.1 47_ Titled “The Control
of Hazardous Energy (Lockout/fagout).” At http://www.osha.gov/pls/oshaweb/owadisp.
show _document?p_id=9804&p_table=STANDARDS.

REFERENCES 407

EM1 sz-0706, Environmental, Health, and Safety Guideline for Semiconductor Man iifacturing
S Equipment. San Jose, CA: SEMI (SeJ!Uconductor Equipment and Materials Inte~onal), 2006.

(Re/aled Information I: Equipment/Product Safety Program is an adjunct to these Guidelines.)
WHS [‘urchasing Guidelines. University of Wollongong, New South Wales, Australia Available at

http:/tus.yhs4.search.yahoo.com/yhs/search?p=HRD-WHS-GUI–070.9+WHS+Purchasing+Gu
ideJines+ZO 13+&hspart=att&hsimp=yhs-att–001&type=att_lego_portal_home.

ADDENDUM A

MOC EXAMPLE 1

ALPHA CORPORATION

Pre

–

Job Plannlng and Safety Analysls Outllne
I. Review the work to be done. Consider both productivity and safety:

a. Break the job down into manageable tasks.
b. How is each task to be done?
c. In what order are tasks to be done?
d. What equipment or materials are needed?
e. Are any particular skills required?

2. Clearly assign responsibilities.
3. Who is to perform the pre-use of equipment tests?
4· Will the work require: a hot work permit; a confined entry permit, lockout/tagout

( of what equipment or machinery), other?
5· Will it be necessary to barricade for clear work zones?
6· Will aerial lifts be required?
7· What personal protective equipment will be needed?
8· Will fall protection be required?

Second Ed’ rife ry Maiwgeme111: Focusing 0,1 Z/0 and Serious !lljury Prevelllion,
© 20 14 Jo~on .. Fred A. Manuele.

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iley & Sons, Inc. Published 2014 by John Wiley & Sons, Inc.

379

–

380 MOC EXAMPLE 1

9. What are the hazards in each task? Consider –
Access Work at heights Work at depths Fall Hazards
Worker position Worker posture Twisting, bending Weight of objects
Elevated loads Welding Fire Explosion
Electricity Chemicals Dusts Noise
Weather Sharp objects Steam Vibration
Stored energy Dropping tools Pressure Hot objects
Forklift trucks Conveyors Moving equipment Machine guardin

10. Of the hazards identified, do any present severe risk of injury? g
11 . Develop hazard control measures, applying the Safety Decision Hierarchy,

• Eliminate hazards and risks through system and work methods design and
redesign

• Reduce risks by substituting less hazardous methods or materials
• Incorporate safety devices (fixed guards, interlocks)
• Provide warning systems
• Apply administrative controls (work methods, training, etc.)
• Provide personal protective equipment

12. Is any special contingency planning necessary (people, procedures)?
13. What communication devices will be needed (two-way, hand signals)?
14. Review and test the communication system to notify the emergency team (phone

number, responsibilities).
15. What are the workers to do if the work doesn’t go as planned?
16. Considering all of the foregoing, are the risks acceptable? If not, what action

should be taken?

Upon Job Completion

17. Account for all personnel
18. Replace guards
19. Remove safety locks
20. Restore energy as appropriate
21. Remove barriers/devices to secure area
22. Account for tools
23. Tum in permits
24. Clean the area
25. Communicate to others affected that the job is done
26. Document all modifications to prints and appropriate files

ADDENDUM B

>

MOC EXAMPLE 3

GAMMA CORPORATION

Pre-Task Analysls

Completed fo~ must be submitted and work must be authorized before
activity is commenced
Submitted by ________ Date ____ Location _____ _
Description of work ____________________ _

Commencement date ______ Expected completion date ____ _

Permits, special skills and licenses: Work must not be.•commenced if required
Permits have not been received or if arrangements have not been made for the
special skills and licenses required.

;:;:–_
Advanced S ,r . .
Second Ed’ ~ety Management: Focusing on ZJ O and Serious ln1ury Preventwn,
© 2014 J ltion._ Fred A. Manuele.

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hn Wiley & Sons, Inc. Published 2014 by John Wiley & Sons, Inc.

381

i :
:
1~
1 -. _,

382 MOC EXAMPLE 3

Permits Required Received
Confined space __ Yes No __ Yes -No
Electrical Yes No __ Yes -No
Combustion equipment Yes No __ Yes __ No
Excavation Yes No __ Yes __ No
Hot work Yes No __ Yes __ No
Lifting-rigging Yes No __ Yes __ No
Fire systems Yes No __ Yes __ No

Obtained
Will special skills be required Yes No __ Yes __ No
Will special licenses be needed Yes No __ Yes __ No

Check off each of the following that apply. Each checke

_ Lockout/fagout _ Pinch points _ Inadequate access
Hot/cold/burns _ Chemical exposure/spill _ Electrical shock

_ Sharp objects Excavations _ Equipment loading/unloading
Asbestos _ Falling objects _ Particles in eye
Elevated work _ Fall from height _ Manual lifting

_ Lighting _ Lifting or rigging _ Mobile equipment
Isolated area Radiation _ Fire/explosion

_ Ladder usage ·_Confined space Heat stress
_ High noise levels _ Scaffolding Inhalation hazard

Other

Other

Other

Other Other

Specify personal protective equipment needed ___________ _

Specify special equipment needed if any——~——
”

H unexpected and unacceptable risks are encountered, it must be understood
that work is to be stopped until the situation is resolved. This provision must be
made clear in pre-job discussions and in employee briefings.

GAMMA CORPORATION 383

1oyee briefings. Supervisors are to assure that all employees involved in the work
·efed on the order of and the procedures to be followed and of risks considered

are n …… J· ob discussions.
intheP”

Naroe Signature Date Name Signature Date —
L—”
,__.
Additiorutl space is provided for the briermgs of personnel added after the work
is co111111enced.

– Signature Date Name Signature Date Name
–
Notifications: Names of persons to be notified before the work is commenced
and after it is completed.

Pre-work commencement
Names

Upon completion

Names

Department

Department

For emergencies encountered, list names and phone numbers of the people who
should be notified.

Names Department Phone Number

Approval signatures

Safety and environmental personnel, who are to assure that foreseeable
hazards have been identified and risk control methods are appropriate

Date ____ _

384 MOC EXAMPLE 3

Manager with authority to approve the project

Upon completion

All personnel, tools and equipment accounted for __ Yes __ No
Operation successfully restored __ Yes __ No

Signature: Project initiator __________ Date ____ _

ADDENDUM C

MOC EXAMPLE 4

A COMPOSITE MANAGEMENT .SYSTEM GUIDE
FOR MOC SYSTEMS

Using several resources on management of change and reflecting on my experience,
the following general statement on a management of change policy and procedures
is offered as a guide for reflection by those who initiate MOC systems. Note that it
encompasses both occupational safety and environmental considerations. It is a brief

‘•!
management guide only and is presented as such. It does not contain any forms. This
composite guide is worthy of thought. It will serve well as a resource in initiatives to
adopt the m1µ1agement of change provisio~s in ZlO.

Management of Change Polley and Procedures: Occupatlonal
Safety and Health and Envlronmental Considerations

1,0verview
This policy defines the requirements for a management of change process wit

h

respect to occupational safety and health and environmental consideratipns.

2,Purpose
This Ii . ., ·
env· po cy establishes a process for evaluating occupational safety and health and

Ironmental exposures when ope_rational changes are made so as to control the

Second Edii ety :,anagement: Focusing on ZJO and Serious Injury Prevention,
la\ 2014 John°~. red A. Manuele.

iley & Sons, Inc. Published 2014 by John Wiley & Sons, Inc.

385

386 MOC EXAMPLE 4

internal risks during the change process and to avoid bringing new hazards and risks
into the workplace.

3. Scope
This policy applies to all operations at this location: there are no exceptions.

4. Responsibility
a. The Management Executive Committee, with counsel from the senior safety

professional, is responsible for establishing processes to determine when these
management of change procedures shall apply, how they are to be implemented
and by whom, and to follow the processes through to an effective conclusion.

b. Facility management is responsible for ensuring that these processes and proce-
dures to address the safety, health, and environmental implications of operational
changes are implemented within their areas of responsibility.

c. Employees at all levels-division managers, supervisors, line operators, and
ancillary personnel-after receiving training on this policy and process, are
responsible within their domains of influence for initiating communications on
operational changes that may have an impact on safety, health, and environmental
considerations and for the implementation of this policy and process.

d. All safety professionals have responsibility to i,dentify operational changes that
require study as to hazard and risk potential and to bring their observations to
management’s attention through their organizational structures.

5. Application
a. This policy applies to all operational changes that may potentially affect on the

safety and health of employees and on our environmental controls.
b. This policy will be implemented as an adj’unct to all issued Safety, Health,

and Environmental. policies and procedures, but particularly to our Design
and Procurement of Equipment arid Facilities Procedure.

c. The senior safety professional, and other safety professionals with particular
skills shall participate routinely in management staff meetings when operational
changes are discussed.

d. A safety professional will sign off on the change plans considering the provisions
of our Design and Procurement of Equipment and Facilities Procedure and on the
New Product Development process.

e. Examples of operational changes to ..yhich this policy and process may apply
include: ·
• Unusual , nonroutine, nonproduction work, work where high-energy exposures

are contemplated, and maintenance projects for which the scope of the work
requires a determination that pre-job planning and safety analysis would be
beneficial

• Revisions in operating methods and procedures
• Revised production goals
• Plans to lower operating costs
• Revisions in staffing levels, upward or downward

A COMPOSITE MANAGEMENT SYSTEM GUIDE FOR MOC SYSTEMS 387

, organizational res~cturing
, Revisions in the envrronmental management system
, New product development
, Adoption of new information technology that has an impact on operations
, Changes in safety, health, or environmental regulations
, Acquisitions, mergers, expansions, relocations, or divestitures

6_ Management of Change_ ~te~ . . . When an operational change 1s identified that requrres study as respects its rrnpact
on occupational safety, health, o~ environmental controls, a person at an _appropriate
management level shall be appointed the maqagement of change champion to chap-
eron the review process to a conclusion.

a. That person, having obtained counsel from safety professionals, will determine
how extensive the review procedure will be and decide on whether:
, Completion ofaManagement of Change Request Form is necessary [Figure 19.1]

within which the accountability and sign-off levels are set forth
, Multidisciplinary group discussions are to be held to encompass the content

of the Pre-Job Planning and Safety Analysis Outline [Addendum BJ
• The hazards and risks that may result as the operational change moves forward

are of greater significance and require appointment of an ad hoc Management
of Change Committee to oversee the project. Safety professionals having the
necessary skills are to be members of such committees.

• Our Capital Expenditure Request Procedure is to be initiated

7. The Management of Change Champion shall:
a. Assure that input on the operational change has been obtained from all who

might be affected.
b. Arrange for resources, staffing, and scheduling to accomplish the change.
c. Schedule the necessary risk assessment.
d. Obtain comments from line operating personnel on their views on how the

hazards and risks can be ameliorated, and their concerns.
e. Get safety personnel to sign off.
f. Follow the review process to a logical conclusion.
g. Arrange a final review of the changes made to assure that hazards and risks

have been addressed properly.
h. :ermine that residual risks, after risk reduction and control measures have
. S n taken, are acceptable.
1. , ee tbat documentation is appropriate.

The Management of Change Champion is to give emphasis to documenting
~I changes made that should be recorded in prints and appropriate files so

h
at persons who make further changes at a later date will know precisely

w at was done.
• : ~~ng decisions_ on what doc~mentation is to be made, this principle is to , l\Y· Be supercautious and consider later needs.

s assessments are to be retained in accord with our document retention policy.

388 MOC EXAMPLE 4

j. Have Standard Operating Procedures modified as necessary.
k. Determine whether additional training is necessary.

8. Training
a. Personnel responsible for safety, health, and environmental training at the

management, supervisory, line worker, and ancillary personnel levels shall
incorporate this policy and process into the training curricula.

b. Employees shall receive training on the revised Standard Operating Procedures
before changes are finalized.

c. In the training process, employees will be p_roperly informed with respect to
their assuming responsibility for the aspects of safety, health, and environmental
matters over which they have control.

ADDENDUM D

MOC EXAMPLE 10

This is S&IH Bulletin 423221, effective date June ‘1, 2008.

LAMBDA CORPORATION

Management of Change Polley for Safety and Envlronmental Risks

1. Overview ‘
This document outlines the requirements for Management of Change with respect to
safety and environmental risks.

2.Purpose
2.1 To establish a process requiring early reviews of vari~us business changes to

diminish the probability of or prevent the occurrence of adverse effects that
may impact the safety of associates, the public, equipment or facilities, and

• I

I

associated environmental aspects.

3.Scope
3. I
3.2

This policy applies to all domestic and international operations .
To address potential impact on safety or environmental issues when various
changes outlined in this process are proposed, and the related management
of those changes.

S ced Safety Ma eecond Edition F nagement: Focu sing 011 Z/0 and Serious Injury Prevention.
2014 John W”i red A. Manuele.

1 ey & Sons, Inc. Published 2014 by John Wiley & Sons, Inc.

389

390 MOC EXAMPLE 10

3.3 For reference only, various fonns may be found in Appendix Section_ 7.~. Othe~
may be hyperlinked to other respective documents or Web pages as indicated in
this document.

4. Definitions . .
4.1 Change Control- Mechanism or tool used by the organization to control

identi fi ed changes in the organization. . .
4.2 Design for Environment (DfE}-An environmental review process for all

products, packaging, and processes in the research and development phase-
includes all new and changed products.

4.3 Due Di!igenre-A pre-purchase/pre-lease or exit audit for acquisitions, divesti.
tures, leases or joint ventures of all business related aspects and real estate propeny
to ensure that potential liabilities are identified.

4.4 Environmental Impact Assessment (EIA}-a reference tool for Environmental
Professionals conducting Environmental Impact Assessments of facility-related
projects, new or modified equipment, new materials and new or modified
processes being implemented at the location.

4.5 Ergonomic Job Analysis/Analyzer (EJA}-An analysis tool used to evaluate
jobs and tasks to rate them by level of ergonomic risk.

4.6 MAP (Management Action Plan}-A tracking tool that incorporates items
identified during an annual operating location self-assessment, or of issues
identified during any of the risk assessments as listed in this policy.

4.7 Production Standards-The value of the production work that has been
determined through methodical evaluation to be reasonably expected during
an allotted time period.

4.8 Project Leader-The term project leader is used in the generic sense. If a person
is assigned the responsibility to manage a project, that person in essence is a project leader.

4.9 S&IH (Safety & Industrial Hygiene)-A Lambda organization within the
technical Resource Group (TRG).

5. Responsibilities
The responsibilities of the personnel required to administer the management of
change process are listed as follows :

5.1 Environmental Professional Resources

EPR shall be responsible for conducting environmental assessments as needed.
This includes, but may not be limited to, an Environmental Impact Assessment.

5.2 S&IH Professional Resources

Maintains this policy and ensures its existence at the affected locations. S&IH
shall_ be responsible for providing the technical resources to comply with the
requirements of this policy. S&IH Professionals shall work with Environmental
Prof~ssionals at the respective operating location

10
ensure compliance to applicable standards.

5.2.1 A review of this policy shall be conducted during the annual self-
assessment or whenever this policy fails to serve the purpose of its intent.

LAMBDA CORPORATION 391

5_2.2 Deficiencies noted in this policy shall be incorporated into the
operating location MAP to ensure that corrective actions are tracked
and completed.

Global Franchise Management Board Members
;.3 Shall ensure compliance with this standard for their respective organizations

described in the scope of this document.
;.4 Line Management

Shall be responsible for ensuring that the requirements and procedures
contained in this policy are implemented and adhered to within their respective
departments.

S.5 Project Leader
Shall be responsible for ensuring that the S&IH Professionals and other
appropriate members of management are informed of upcoming projects,
and that any safety related issues are resolved prior to the project completion
per the requirements of this policy.

6. Policy Statements
6.1 Due-Diligence Process

A Due-Diligence study of the prospective acquisition and divestitures shall
be conducted to determine strengths and weaknesses of the business, and the
impact on safety and environmental requirements.

6.2 Preliminary Environmental, Safety & Health Assessment Questionnaire
A Preliminary Environmental, Safety & Health Assessment Questionnaire
shall be initiated during the project design/planning phase by the Project
Leader and submitted to the primary S&IH Professional at the operating
location.

The questionnaire will help ensure that the S&IH and Environmental
professionals complete the appropriate risk assessment(s) and associated
forms. Assessment information will be forwarded to the project leader
for inclusion in the project plan. (See Form-Section 7.1, Appendix I,
Preliminary Environmental, Health & Safety Assessment Questionnaire.)
6.2.1 Program Elements shall include the following:

6.2.1.1 What is the basis for the proposed change?
6.2.1.2 What is the time period for the change?
6.2.1.3 What assessments of the pr~posed change will be required?
6.2.1.4 From an Environmental, Health & Safety perspective, what

are the “‘things to consider” when making the change?
6.2.1.5 What are the related Environmental, Health & Safety autho-

rization requirements for the proposed change?
6.3 Design for Environment (DfE)

Each operating location shall develop and implement a Management system to
ensure that the Design for Environment (DfE} Tool Assessment is performed
and documented for all products, packaging, and processes in the research and
development phase (all new and changed products).

I

392 MOC EXAMPLE 10

6.4 Evaluating Change (Risk Assessment Guidelines)-_Requirements
The respective S&IH and Environmental professionals shall work with
those responsible for implementing the change to ensure that the appropriate
assessments are completed and to determine what actions need to be taken
during the design phase.
6.4. l Changes in any one of the following areas can have significant impact

on the safety of associates, the public, the environment, equipment and
facilities, and shall require one or more risk analyses to be conducted
to determine needs early in the planning process. Identified needs shall
be included in the operating location MAP to ensure that corrective
actions are brought to closure.
6.4.1.1 New Process Product Development

Development of a new process or a product shall be reviewed
for their potential impact on associates and the public relative
to exposure, and safe handling of process components and
equipment and products.

6.4.1.2 Facility (Construction/Renovation) Project
New facility construction and/or renovation to existing
facilities shall be reviewed for their potential impact on life
safety, environmental aspects, and other related needs prior
to occupancy. ·

6.4.1.3 Capital/Non-Capital Project
New capital projects shall be reviewed to ensure that safety
or environmental issues are identified. While “replacement in
kind” (purchase of like equipment) typically does not impact
change, capital projects should be evaluated so that advances
in safety or environmental technology, or changes in related
regulations can be incorporated as part of the project. This
includes the purchase of computeri;, other similar equipment,
and/or wo~ksll\tiqps to en~Hre that t!te workstations. that w~l
be used with the computex:s and other similar equipment is
appropriate f9r the job/offic~. ‘

6·4· 1.4 Existing Product Process Modification
Upgrades or m~fications to current operating processes
or products such as improvements based on technological
advanc~~ents or safer chemical components shall be reviewed
f~r therr inherent risk and how the change may affect asso-
ciates or existing systems, processes, and/or equipment.

6.4.1.5 External Manufacturing 1
A manufacturer of Lambda products or components sha!l
be evaluated for appropriate compliance to 1safety and en~t-
ronmenta\ standards. (See Fonns-Section 7.3 Appen~tx
ID, Safety & Industrial Hygiene External Manufactunng
Checklist, and Section 7 .4, Appendix IV Environmental
External Manufacturing Checklist.)

LAMBDA CORPORATION 393

6.4.1.6 Method~ or Procedures & Production Standards Changes to
production ~ethods, procedures, or production standards,
shall be reviewed for safety to ensure th t th . rl · th . a e associate
pe omung e work is not placed at risk. Documents relative
to those methods o~ procedures, such as Job Safety Analysis
(~SA), shall be revised and communicated to affected asso-
c,iates. The evaluation shall include an Industn’al H . . if h . yg1ene
review c eimcals are used and an Ergonomic Job Analysis
(EJA) if production standards have been modified.

6.4.1. 7 Product or Equipment Transfer
Product and/or equipment transfer from one operating location
to another can adversely impact the receiving location in a
number of ways. It is imperative that the location transferring
the product/equipment obtains the services of the safety
and environmental professional(s) at the operating location
receiving the product/equipment to communicate anticipated
needs or modifications at the receiving location. Operating
locations transferring equipment shall either ensure compli-
ance of the equipment with applicable standards or communi-
cate and document those deficiencies to the receiving location.

6.4.1.8 Business Acquisitions
New businesses introduced to the Lambda family of com-
panies typjcally are not familiar with Lambda’s stringent
safety or environmental requirements. It is therefore imper-
ative to introduce the new business to Lambda requirements
as ~arly as possible after the acquisition.

6.4.1.9 Significant Downsizing/Hiring
In periods of significant downsizing or hiring, S&IH shall be
included in management discussions in order to anticipate
potential impact the change may have on the business.

6.4.1.10 Changes In Management
The attitudes, beliefs and values of management, particularly of
top management, relative to safety and enviro~ental issues,
will set the standard for the operating location. New members of
management who have been recruiteq from outside of Lambda
must become familiar with their rolb and responsibilities to
obtain their support in achieving desired results. Likewise, tho~
who have been promoted from within should reaffinn therr
support to the resolution of safety and environmental issues.

6·5 Conducting Risk Analysis-Assessment Formats
6.5.1 Safety Strategy Checklist .

The S&IH professional shall complete the Safety Strategy Checklist
f9r all projects associated with _new proce~s/prod~ct development,
facility construction or renovations, and capital proJect~. Upon com-
pletion, this document shall be reviewed with the proJect leader to

6.6

–

394 MOC EXAMPLE 10

identify safety-related needs·early in the process· for incl .
F -S ti us1on • Development Phase. (See onn ec on 7 .2, Appendix n 1n the

Strategy Checklist.) . . . ‘ Safety
65.2 Post Production Safety Qualification Operation Review lhe S&

Professional, who cmr~pleted the EIQ s.afety review, shall com le
document, which is then kept on file m the Safety Depllt”h.. P te this

. . ted d . -1.U1ent at th operating location. Observations no unng the original Safi e
process shall be documented, ‘and · action scheduled for a ety ~Q
within 180 days from the date ·bf the · original safety EIQ. ,;-r~view
Professional is •responsible for ensuring that the post reviewe &l}f
within the prescribed time frame. Action items that have n
corrected are to be flagged as “repeat” observations, and conunu: n
to the Qualification Coordinator for follow up. cated

6.5.3 Ergo Job Analysis/Analyzer (FJA)
This tool shall be used to ensure that modifications made to method
procedures; or RE’s do not pose an increased risk to the associa~
performing the job and/or task.

6.5.4 Environmental Impact Assessment
The Environmental Professional at the operating location where the
modifications will be made, will include all environmental aspects of
the modifications in the facility’s assessment, and will use the results

· of the assessment to implemenr actions in accordance to the facility’s
Environmental Management System.

6.5.5 Due-Diligence
·rn the event of an acquisition, lease, joint ·venture or divestiture, an
audit of the prospective business and · real estate property shall be
conducted by appropriate company individuals or a contracted third
party. The purpose is to ensure that potential liabilities are identified
prior to closure of contracts. The due-diligence report shall be gener-
ated by those individuals in order to develop a plan to bring the
business under compliance of all Lambda guidelines within pre-
scribed . time frames from the date of the acquisition according to the
level of requirement as listed in the Lambda Acquisition Guide.

6.5.6 . Design for Environment (DtE)
, The concept portion of this tool is to be completed during the Conceplt

· thi too -. ~.tage of new product development. The design portion of s uct
, 1s to be completed during the Development Stage of new prodth·s

development. It is the Project Team’s responsibility to complete
. tool for all new and changed products with ·the assistance and suppo
of Environmental Professionals.

Procedure · .
1 6 6 1 At th b · · · , the ProJec

• •• 1 e ~gmrung of the projects design/planni~g phase, & safetY
Lefider wdl compl~te th: Preliminary Environmental, ~eal~ D), and
~ssessment Questionnarre (see Form-Section 7.1 Appen~ safetY
forward the completed form to the Environmental, Health . pacted
Professionals located at the operating location that will be iII1

LAMBDA CORPORATION 395

by the change. If an Environmental, Health & Safety Professional is
not physically located at the operating location, the completed
Questionnaire shall be sent to the Environmental, Health & Safety
Professional responsible for that location.

6.6.2 Toe Environmental, Health & Safety Professionals, as a minimum,
shall contact the Project Leader to discuss the proposed project in
order to ascertain the level of evaluation required for the project.
Evaluations shall include, but are not limited to, the types of checklists
found in the Appendices of this policy.

6.6.3 Assessment information will be documented and forwarded to the
Project Leader for inclusion in the project plan.

6.7 Training
Management shall be trained in the operating requirements of this policy
to ensure its consistent application to business change. Associates involved
in operating a new process or technology, or whose safety would otherwise
be affected by the change shall be informed of, and trained in, the change
prior to its implementation. This training must be documented.
6.7.1 The associate training, at a minimum, shall include:

6.7.1.1 Overview of the changes that will affect them.
6.7.1.2 Any riew or modified requirements governing those changes

[i.e., personal protective equipment (PPE), chemicals, facility/
area .layout, evacuation routes, ergonomic related issues,
machine guarding, etc.).

6.7.1.3 A r~view of any ‘procedures, i.e., operational and/or safety,
i.e., JSA’s, process specifications, etc., that have been changed.

6. 7 .1.4 Introduction of any new procedures that are under development
in order to gain input from those whom the changes shall
;lffect most.

Z Appendices
7.1 Appendix I-Preliminary Environmental, Health & Safety Assessment

Questionnaire
7.2 Appendix II-Safety Strategy Checklist (Not available)
7.3 Appendix ID-Safety & Industrial Hygiene External Manufacturing

Checklist (Not available)
7,4 Appendix IV-Environmental External Manufacturing Checklist (Not

available) .
7·5 Appendix V-Environmental Impact Assessment Checklist

396 MOC EXAMPLE 10

LAMBDA CORPORATION

PRELIMINARY ENVIRONMENTAL, HEALTH AND SAFETY
ASSESSMENT QUESTIONNAIRE

1
• _,

Possibly Triggering a Safety Review

For Intra-Computer Access Enter-Lambda S&IH Appendix I
Project leader’s name and phone number—-‘-____ Date ___ _

Enter an “X” in each box that pertains to this project and send the form to S&IH. If an
“X” is entered in any box, a Safety Review by S~IH and En~ironmental Professionals.

1. ____ Project includes purchase of new equipment, iricluding com-
puters and associated workstations.

I I ‘ I I ‘

2. ____ Modification or addition tq pie existing facility.

Change ,, . . . ;. j • ;
3. ____ To the current energy source~ (electtjc, hydrauli<;:, pneumatic, etc.) 4. ____ To machine guarding 0r electrical ,safety systems. 5 . . ___ , ·1 __ Involves the use ·of a new chemical. . '

.·’ l ·1 ,,, l ,.1
6. Involves the use of a biological agent.

• • _, • l

7. __ -_Affects P,ers9n protective equipment requirements
8. __ ___.__ Results in increased noise, vibration, fumes, vapors, radiation,

‘ _ · te!llperature, etc. . .
9. ____ Results in increased chemical ·storage requirements or increased

chemical utilization .
. 10. ____ Affects. manua.J, _materi,aJ handling requirements (weight, force,

frequency, container capacity).
11. ____ Affects exhaust system requirements~
12. ____ Impacts on Operators work stations, tools, equipment, etc.
13. . Impacts on production procedures; pr9duction’ output expecta·

t10ns, or work methods. · ‘ ·
14. —- Results in an incre.ase or decrease of Operators. · .
15. Results in greater risk.to e~ployee·s who are not operators.

Project Leader signature ———-
For Safety & IH Use Only

16· —- Safety Assessment Required
17. —- Ergonomics Job Analyzer Required
18· —- No Further Required

Signature S&IH ———– Date _____ _

.asDA CORPORATION
LA1v•

LAMBDA CORPORATION 397

RONMENTAL IMPACT ASSESSMENT CHECKLIST eNVI
t. ra computer Access, Enter-Lambda S&IF Appendix v For In ,
AIITha Ar Im acted

h

Air 1mpacts on fa~ili_ty poten~al to emit
– Impacts on exist.mg penruts
– Requires permit applications
– Implications – pollution control/MACT – Other –
wastewater

Impacts on existing permits
– Requires permit applications = Affects treatment systems

Other

Asbestos
_ Fume hoods impacted
_ Survey verification required
_Continuous sampling required

Other

Drinking Water
_ Impacts on cross connections
_ Treatment systems impacted
_ Sampling plans needed
_Other

Community Impacts
-LegaVCommunications
-Noise
-Other
Facilities
– PM/Calibrations
– Water connections/Drains
.__ Water conservation
.__ Energy connections/Conservation
.__ Ventilation connections
— Drawings/Surveys
–other

Reporting/Reg. Triggers
_FIFRA
_TSCA
_TRI
_CRTK
__ p Listed waste
__ Risk Management/Planning
__ Other

Non-Hazardous or Hazardous Waste
__ Segregation
__ Collection
__ Shipments/Generation rate
__ Storage

Other

Chemical Management
__ Labeling
__ Storage/Grounding
__ Segregation/Spill prevention
__ Inventory

MSDS needed
Pharma/Controlled substances
Other

Emergency Response
__ Emergency preparedness
_ Plans/SPCC plan

Other

EMS
__ Management Review
__ Commitment and Policy
__ Environmental Planning
__ Implementation and Operations
_ Training (RCRA, DOT)

Other

398 MOC EXAMPLE 10

Environmental Action Plan

Issue Description Follow-up Action Responsible Party Schedule
–
–

Comments _______________________ _

Date of Action Plan Completion ________ _
Project Leader Sign-Off ________ Date ____ _
Environmental Sign-Off Date ____ _

CHAPTER 19

MANAGEMENT OF CHANGE:
SECTION 5.1.3 OF 210

Section 5.1.3 in ANSI/AIHA Zl0-2012 is entitled “Design Review iµid Management
of Change.” As was said in Chapter 15, “Safety Design Reviews,” the processes for
design reviews and for management of change are major elements in a safety and
health management system. Although they have some common characteristic,:s, they
are implemented through d jstinctively separate management processes. . ,

One of the reasons that the management ,of cliange process in addressed s_ep~ately
is to promote .an understanding and application of the change analysis .concept on
which it is based. In this chapter we: . .

• Make the case that having an effective Management of Change System (MOC)
in place as a distinct element in a safety and health management system wil

l

~educe the potential for serious injuries and fatalities, one of the focus poi,its
In this book. (Effective MOC system~ ._ also reduce the potential for injuries,
environmental damage, and other forms of damage at all levels of severity.)

• Intr~~ce the change analysis concept and relate it to the management of change
prov1s10ns in ZlO. ,

• Cite statistics in support of having effective MOC systems in place.
‘ Defi h ne t e purpose and methodology of a management of change system.
• ~~ta~lish the significance of management of change as a m~thod to prevent serious

InJunes and fatal ‘t1’ · 1 es.

Second &r afety Management: Focusing on ZJO and Serious Jnji1ry Prevention ,
© 2014 Jo:::ion. Fred A. Manuele.

Wiley & Sons, Inc . Published 2014 by John Wiley & Sons, Inc.

359

I !

I
f
:!

360 MANAGEMENT OF CHANGE: SECTION 5.1.3 OF 210

• Outline management of change procedures, keeping in .mind the staffing
limitations at moderate-sized locations and their need to avoid burdensome
paperwork. 4 ‘ • •

• Provide guidelines on how to initiate and utilize a MOC system.
• Emphasize the significance of communication and training.
• Include examples of four management of change systems in place and provide

access to six other real-world MOC systems.

ON CHANGE ANALYSIS

Change analysis is a commonly used process. Inquiry through an Internet search
engine will show that the. liter.ature on change. analysis is abundarit. A few examples
related to safety follow. OSHA say~ this abou•t change analysis in · Saf;ty, & Health . r ,
Management System eTool-Worksite Analysis: ‘ , :

Anytime something new is brought into the workplace, whether it be a piece of
equipment, different materials, a new process, or an entirely new building, new
hazards may unintentionally be introduced. Before considering a change for a
worksite, it should be analyzed thoroughly beforehand. Change analysis helps
in heading off a problem before it develops.

In the Aviation Ground Operations Safety Handbook, 6th edition, change analysis
is listed within “The .. Risk Management Process” as a ·inethod “to detect the hazard
implications of both planned and unplainied change.” ‘(p·. 10)
:, In MORT Safety’Assurance·Systems, ,William Johnson makes references to change
analysis throughout the book as he discusses applying the “Management Oversight
and Risk Tree (MORT)”. In System Safety for the 21st Century, Richard Stephans has
a ch’apter entitled “Change Analysis.”

Provisions for design reviews and management of change are also contained in other
standards and guidelines, perhaps by other names. For example, in Quality management
systems-Requirements, ANSIIASQ Q9001-2000,-Section 7.3.7 is titled “Control of
design and development changes.” It reads as follows:

l

Design and development changes shall be identified and records maintained.
The changes shall , be -reviewed, . verified and validated1 as appropriate, ,and
approved before. iipplemeptation1.The i:eview, of design and

,shall) nclude e,vf11uatip.n of ~e effe~f of the changes on constituent p~ and
product already delivered. Records of the results of the review of changes, and
any necessary actions shall be maintained.

Change analyses are made to assess the consequences of a change on a broad
scale and to provide a’ base for planning the change to assure that succes~ is achieve_d
and that negative consequence.& are as few as,reasonably practicable. Ch,ange analysis

STUDIES THAT SUPPORT HAVING A MOC S,YSTEM IN _PLACE 361

. th fundamental process on which the MOC provisions .in ZlO are built. Literature :n c~ange analysis is abundant. Throughout the liter11ture, emphasis is given to:
‘ .

, Pl~ning for the change process, as,in ZlO’s Section 4.0
, Attempting to foresee the obstacles that could arise
, Repeated communication
, Involving all personnel who are affected by the change
, Being aware of the normal resistance to change that many ,of the persons involved

may demonstrate and its probable intensity
, Going gradually, step by step, if that is .practicable
, The additional training that may be required
• Appreciating the extent of the culture change that will be necessary if the process

change is to be successful

STUDIES THAT SUPPORT HAVING A MOC SYSTEM IN PLACE

Three significant studies establish that having a management of change system as an
element within an operational risk management system would serve well to reduce
serious injury potential.

Reviews made by this author of over 1800 incident investigation reports, mostly
for serious injuries, support the need for and the benefit of having MOC systems.
They showed that a significantly large share of ,incidents resulting in serious · injury
occurs:

‘ ‘
unusual and nonroutine work is being performed

• In nonproducti.on activities
• In at-plant modification or construction operations (replacing a motor weighing

800 pounds to be installed on a platform 1? feet above ~e floor)
• During shutdowns for repair and maintenance, and during startups
• Where sources of high energy are present ( electrical, steam, pneumatic, chemical)
• Where upsets occur: situations going from nbrmal to abnormal

. / . l

Having an effective MOC system in placeciwould have served to reduce the
P~obability of serious injuries and fatalities occurring in the operational categories
8 own above.

res~t~dy led by Thomas Krause, chairrn~~ of th~ b.?!11:d at BST in 2011 produ~ed
co . s 10. support of having MOC systems in place. (Data were provided in pe~sonal
co lllinu~ication with Krau·se. BST is’ tb’ publish a paper including these data.) Seven
fo~Pantes Participated in the study. Shortcomings in pre-job planning, another name
fat:{t;nagem~nt of change, were found in 29% of incidents that had serious injury or
app y ~otential. Focusing on reducing that 29%, a noteworthy number, would be an

ropnate goal.

362 MANAGEMENT OF CHANGE: SECTION 5.1.3 OF 210

Correspondence with John Rupp at ~uto ‘York_ers in Detroit confirmed the
continuing history with respect to fata~ttes occumng 1~ UAW~re~resented Work.
places. A previously issued UAW bulletin (no long~r available) md1cated that from
1973 through 2007, 42% of fatalities occurred to skilled-trades workers, who repre

–

sented about 20% of the membership. ·

Additional data provided by Rupp for the years 2008 through 2011 indicated that
47% of fatalities occurred to skilled-trades ~ork~rs. The point is that skilled-trades
workers are not in routine production jobs. ‘ijiey are often involved in unusual and
nonroutine work, at-plant modification or construction operations, shutdowns for
repair and maintenance, startups, and where sources of high energy are present. That
is the sort of activity for which’ a MOC system would be beneficial.

PURPOSE OF A MANAGEMENT OF CHANGE SYSTEM

Although the tenn management of change is not defined in 210, its purpose is clearly
established. Appendix H-Management of Change–provides guidance on what the
writers of Zl O intended. With respect to operational risks, the MOC process is to assure that

• Hazards are identified and analyzed and risks are assessed.
• Appropriate avoidance, elimination, or control decisi9ns are made so acceptable

risk levels are ci9hieved and ~tained throughout the change process.
• New hazards are not knowingly brought into the workplace by the change.
• The change does not have a negative impact on previously resolved hazards.
• The change does not make the potential for harm of an existing hazard more severe.
• The occupational safety arid health man~gement system is not affected negatively.

APPLICATION CONSIDERATIONS ·
. ‘

In the following list of categories to which the management of change process could
apply, subjects oth~r tl}an for the safety of employees are included to demopSttate
the breadth of benefits that could be obtained from an effective MOC syStem.
Consjderation would be giver\, as ~pplicable, to:

• The safety of employees making the changes
• The safety of employees· in adjacent areas I,
• The safety of elllployees who will be engaged in operations after changes are made
• Environmental aspects
• Safety of the public
• Product safety and product quality . 1
• Fire protection so as to avoid property damage and business interruption

EXPERIENCE OF OTHERS IMPLIES OPPORTUNITY 363

stated in ES.1.3 in Z 10,. the management of change provisions may apply when
As · h l . t ·1·. es are made m tee no ogy, eqmpmen , 1aci ities, work practices and procedures,

chang · t ·al · · al . specificauons, raw ma en s, orgaruzation or staffing changes affecting skill
design d .

b·liu·es and standar s or regulations. capa t ‘ OSHA ‘s Rule [or Pro~ess Safety M~nagement of Highly Hazardous Chemicals, 29
cFR 1910.119, issued m 1992, requrr~s that an ~pe.ration affected by the standard
have a management of change process m place. Similar requirements do not appear
in other OSHA standards. . .

However, as shown previously, change analysis (management of change) was an
element in OSHA’s Safety & Health Management System eTool-Worksite Analysis.
Also, having a MOC system in place is a requirement to achieve OSHA’s VPP desig-
nation (OSHA’s Voluntary Protection Program).

ASSESSING THE NEED FOR A FORMALIZED MOC SYSTEM

Useful data can be developed on the need for a formalized MOC system through
a risk assessment initiative and a study of an organization’s incident experience and
that of the industry of wlµch the organization is a part. Workers’ compensation claims
experience can be a valuable resource for such a· study.

To develop meaningful and m~nageable data, ,it is proposed Jha~ a computer run be
made of an organization’s claims experience covering at least three years, to select
out all claims valued at $25,.000 or more-paid and res~rved. If experieµce in other
organizations is a guide, the computer fUn will probably encompass .. b~tw.een 6 and
8% of the total number of claims and from 65 to 80% of the total costs.

An analysis of the data acquired should be ~ade to identify job titles and incidents
that have occurred when changes were taking pl~ce, and to determine whether th~
resulting data support proposing a formalized MOC system. If available, industry
experience, such as through a trade association, should also be part of the study.

If it is found that very few incidents resulting ‘ in’ serious , injury occurred when
changes were being made, that should not deter proposing that the substance of a
Moc system be applied for particular changes that present serious injury potential.

EXPERIENCE OF .OTHERS IMPLIES OPPORTUNITY

J0 test Whether personnel in operations other than chemicals had recognized the need
~:~d devel?ped management of change systems, assi~tance ~f ~e st~ at the
Ar ncan Society of Safety Engineers responsible for practice ~pecialti~s was soug~t.

f
equest was sent to members of the management specialty group asking that copies

0 Moc · procedures for operations other than chemicals be forwarded. The response
was overwh 1 · · · d th’ e mmgly favorable The number of documents receive was more an
cou\ct b ·

Ex e practicably used. . , . .
reco a~ples received demonstrate that managements m a variety of operations

gnized the need to have MOC systems in place. Four real-world MOC systems

364 MANAGEMENT OF CHANGE: SECTION 5.1.3 OF 210

are addenda to this chapter. Because of space co~i;ider~ti_ons, all of the examples are
not included here. But, as will be shown later, six additional MOC systems can be
accessed by going on the Internet. These 10 MOC systems were selected specifically
to show:

• The broad range of harm and damage categories covered
• Similarities with respect to subjects covered
• The enormity of the variations in how those subjects are addressed

These examples are real-world applications that display the substance of MOC
systems in place.

HISTORY DEFINES MOC SYSTEM NEEDS AND DIFFICULTIES
IN THEIR APPLICATION

At least 25 years ago, personnel in the chemical and process industries recognized
the importance of having . a management of change process in place as an element
within an operational risk management · system. That awareness developed because
of the number of major accidents that occurred when changes were taking place.

In 1989, the Center for Chemical Process Safety issued Guidelines for Technical
Management of Process Safety, which included a maqagement of change element.
In 1993, the Chemical Manufacturers Association published A Manager’s Guide
to Implementing arid Improving Management .of Change_ Systems.

In 2008, the <;enter for Chemical Proce~s Safety issued' Guidelines for Management of Change for Pro~ess Safety. It builds. on and considerably extends the previous publications. These comments ap~ear i~ the Preface: ·

I I ! • I ‘
The concept and need to properly manage chang~ are not new; many com-
panies have imple~ented m~nagei:nent of chapge (MOC) systems. Yet inci-
dents and near misses attributable io inadequate MOC systems, or to subtle,
previously unrecogniz~d sotirces of change (e.g., organizational changes),
continue to occur. To improve the performance of MOC systems throughout
industry, managers need advic;e on how to better institutionalize MOC systems
within their companies and faciliti es andl t~ ~dapt

0

‘ such systems to managing
non-traditional sources of change. (p. xiii)

Note th~t incidents and near misses (~ear hits) that are attributable !o, in.adequate
MOC systems continue to occur. Also, recognition is given to organizational chan~es
as a pre~iou~ly unreco~nized so~rce from which maqagement of change difficulties
could anse. Authors of the Guidelines recognized that:

Management of Chang~ ,is one of the most important elements of a process
safety management system. (p. 1) ·

THE MANAGEMENT OF CHANGE PROCESS 365

ntE MANAGEMENT OF CHANGE PROCESS

. the case with all management systems, an administrative procedure must be
As_ is to communicate what the management of change system is to encompass and
wntt~tn·s 10 operate. Care should be taken to assure that the MOC system is designed hOWl 1 •
to be compatible with:

, The organization’s and industry’s inherent risks
, Other relevant management systems in place
, Toe organizational structure
, Toe dominant culture
, Toe expected participation of the workforce

Although brevity is the goal, consideration should be given to the following as
subjects are selected for inclusion in a MOC procedure:

I. Defining the need for and the purpose of the MOC system
2. Establishing accountability levels
3. Specifying the criteria that are to trigger the initiation of formal change requests
4. Making clear how personnel’are to submit change requests, and specifying the

change request form to b~ used
5. Outlining the criteria f9r request reviews and the responsibilities for reviews

‘ .
6. Indicating that the f’4OC system is to encompass:

a. The risks to the workers who are to do the work and other employees who
are affected

b. Possible damage to the property, and business interruption
c. Possible environmental damage
d. Product safety and quality
e. The procedures to ·accomplish the change

I I

f. How the results are to be evaluated
7. Establishing that minute-by-minute . control · is to be maintained to achieve

acceptable risk levels, ,and that risk assessments will be made as often as
necessary as the work progresses ,.

8· Giving instruction on the action to be taken if, as the work proceeds, unanticipated
risks of concern are encountered

9
· ~ssigning responsibility for acceptance or declination of the change request,

Including MOC approval form
IO, Outlining a method to determine the actions necessary because of the effect of the

changes (e.g. , additional training of operators and maintenance workers; revision

11 of
standard operating procedures and drawings; updating emergency plans)

· 1ndicating that a final review of the work will take place before startup of
operations, and identifying the titles of the persons who are to make the review

366 MANAGEMENT OF CHANGE: SECTION 5.1.3 OF 210

RESPONSIBILITY LEVELS

In drafting an MOC system, responsibility levels must be defined ~d be in accord With
an entity’s organizational structure. This is a highly important step m ~eveloping a MOC
system. In an entity where even minor chapges in a process are considered critical with
respect to employee injury and illness potential, possible environmental contamination
and the quality and safety of the product, the levels of responsibility can be many. ‘

Responsibility levels are set forth clearly in some examples of MOC systems,
but not in others. Examples of levels of responsibility, as outlined in an organization
where the inherent hazards require close control, are shown here as reference points
in drafting MOC systems.

Initiator: The initiator owns the change and is r~ponsible for initiating the change
request form. If the complexity of the proposed change requires, the initiator’s
responsibilities may be reassigned at any time d~ng the change process. The
initiator will fully describe and justify changes, ensure that all appropriate depart-
ments have assessed the changes, manage the execution of the change request,
and ensure that the changes are implemented properly.

Department Supervisor: The department supervisor has ·the responsibility to assign
q~ed personnel to initiate change requests. The change control process is criti-
cal to the safety of our employees, an av9idance of ~nvironmental contamination,
and the quality of our products. The departmental supervisor is responsible to
ensure that the change request is feasible, and presented adequately for review.

Document Reviewers: Document reviewers will review and approve change
request forms. The review/approval activities include a review of the document
for accuracy and adequacy with respect to the changes proposed.

Approvers: Department managers will select pre-approvers with expertise-related to
the nature of the proposed change. Each reviewer will be responsible to evaluate
and assess the impact of the proposed change on existing processes in his or her
area of expertise. The reviewers must also review and approve the change request
form and the implementation plan to evaluate the change and assure that the steps
for implementation are appropriate. This is the final ‘review before the proposed
change is implemented.

Pos!-lmplementation Approvers: Department managers will select post-implemen~ti~n
~~ers who are to assure that the change has been implemented appropnate Y
as m

assure that only the changes shown on the change requ~t form have been
lillplemented.

ACTIVITIES FOR WHICH THE MOC PROCESS
SHOULD BE CONSIDERED .

Hazard· and ·risk c 1 · · ak place . . . omp exities of an organization in which change is to t e Jy
and the desirability of establishing a MOC system that is adequate but not o~e\r
complex should be kept in mind when selecting the activities that are to trtgg

MANAGEMENT OF CHANGE REQUEST FORM 367

. . g the MOC system (see Appendix Hin ZlO). A list follows from which
acuvaun 1 d . . categories can be se ecte . ac11v1ty

, Non-routine and unusual work is to be performed
, The work exposes employees to sources of high energy
, rypes of maintenance operations for which pre-job planning and safety reviews

would be beneficial because of inherent hazards
, Substantial equipment replacement work
, Introduction of new or modified technology
, Modifications are made in equipment, facilities, or processes
, New or revised work practices or procedures are introduced
, Design specifications or standards are changed
, Different raw materials are to be used
, Modifications are mad~ i_~ he~ih ~nd safety devices ~d equipment
• Significant changes occu~ in the site’s organizational structure
• Staffing changes in numbers or skill levels are made that may affect operational risks
• A change is made in the use of contractors

MANAGEMENT OF CHANGE REQUEST FORM

Developing a management of change request form is a necessity, and the content of
the form should be in concert with an organization’s structure and other management
systems in place (e.g., capital expenditure request, work orders, purchasing proce-
dures). Saving the form as a computer file allows flexibility when descriptive data
and comments are to be added. A list follows of subjects to be considered in drafting
the request form.

‘ Name of person initiating the request.
‘ Date of request.
‘ Department, section or ~ea.
‘ The equipment, facility, or processes affected
‘ Brief description of the proposed change and what is to be accomplished by it.
: Potential performance, safety, health, and environmental considerations.

litles and space for entering the names of personnel who are to review the change.
‘ The effect the change may have on standard operating procedures, maintenance,

and training, etc.
I s
, Pace for reviewers to enter special conditions or requirements.
, Approvals and authorizations.

Routin . d’ . t g in tcators or provisions for copies to be sent to personnel responsible
or trainin d • · g an updaung operating procedures, drawmgs, etc.

368 MANAGEMENT OF CHANGE: SECTION 5.1.3 OF 210

Management or Change Request Form

General Information
Date Originator

Department

Sent to:
Equipment, facility or process effected
Urgency of change: _Emergency _Priority

_Routine

Basis for the Change (Check those applicable)
_ Improved safety-risk reduction
_ Improved performance-efficiency
_ Pollution prevention-waste minimization

_ Essential to operation ‘
Other –

Description of Proposed Change and Potential Hazards ‘ }
Summarize the technical basis for the proposed change and any potential safety, health, or
environmental impacts from the proposed change. Describe how the change will affect
SOPs, maintenance, training, etc. State the change start _and end dates.

Approved or disapproved by

Name and date Organization/Position

Comments
L

–

–
–

FIGURE 19.1

Figure 19.1 is an example of a management of change request form . Others maY
be found in some of the examples in the addenda to this chapter. As would be expe~ted,
each form was developed to reflect the views and needs of a particular organizauon.

IMPLEMENTING THE MANAGEMENT OF CHANGE PROCESS
· ·tude of

Senior management and safety professionals must appreciate the magni t
the task they face when initiating activity to implement a MOC system, E,xpe:
pushback: egos get in the way; territorial prerogatives may be maintained ; t e . tance to
power structure may present obstacles; and the expected and normal rests ‘th
change can be huge since the people affected may have had little experience wt
the administrative systems being proposed.

IMPLEMENTING THE MANAGEMENT OF CHANGE PROCESS 369

Although MOC sy~tems have _been ~uired in the ‘chemical industries for many
the literature indicates that difficulties have been encountered in their application.
co(llJllents occur in Guidelines for Management of C~nge for Process Safety:

Even though the concept and b~n~fi~s of managing change are not new, the
aturation of MOC programs w1thm industries has been slow, and many com-

;anies still struggle with implementing effective MOC systems. This is partly
due to the significant levels of resources and management commitment that are
required to implement and improve such systems. MOC may represent the
biggest challenge to culture change that a company faces . (p. 10)

Developing an effective MOC system may require evolution in a company’s
culture; it also demands significant commitment from line management, depart-
mental support organizations, and employees. (p. 11)

Management commitment, evidenced by providing adequate resources and the
leadership required to achiyv,e the necessary culture change, must be emphasized.
Stated or written management commitment that is not followed by providing the
necessary resources is not managemynt commitment. Be.cause of the magnitude
of the procedural revisions, necessary when a. MOC system is initiated, it must be
recognized that methods to achieve a culture change are to be applied. A list follows
of subjects to be considered in an attempt to successfully implement a MOC/Pre-Job
Planning system.

• Management commitment and leadership rhust be obtained and demonstrated.
That means providing personal direction and involvement in initiating the pro-
cedures, providing adequate resources, and making the appropriate decisions
to achieve acceptable risk levels when there is .disagreement in the change
review process.

‘ Keep procedures as simple as practicable. A less complicated system that is
actually utilized achieves better results that an unused complex system.

‘ A goal is to obtain widespread acceptance and commitment
‘ Communicate extensively. Infonn all affected employees in advance of a decision

to ini~ate an MOC system, solicit their input, and respect their perspectives and
concerns.

‘ Recognize the need for and provi’de the necesJary training.
‘ If practicable, go sl~~-step by step.
‘ Field-test a system prior t~ implementation. Debugging pays off in the long run.
‘ After the system is refined through a field test, select a job or an activity for which

a Moc system would be beneficial for both productivity/efficiency and safety.
‘ Tbe purposes of testing the MOC system in a selected activity are to:

‘ Demonstrate the value of the system
• Achieve credibility for it , .
‘ Create a demand for additional application of the system

370 MANAGEMENT OF CHANGE: SECTION 5.1.3 OF 210

• Emphasizing the potential efficiency ben~fit of a_ MOC system i~ encouraged,
Doing so should result in more favorable interest m the system bemg proposed.

• Monitor the progress and performance of the system through periodic audits
and through informal inquiry of employees on their perspectives.

MANAGING ORGANIZATl(?NAL CHANGE

In some of the examples given in this chapter, procedures require that risk assessments
be made of the significance of organizational changes. Those procedures exist because
it has been recognized that organizational and personnel changes can have a negative
impact on the effectiveness of an operational risk mahagement system.

Although there is considerable literature on the subject, I have chosen Managing
the Health and Safety Impacts of Organizational Change as a reference because it fits
closely with the intent of some of the examples of MOC system included in this
chapter. The publication was issued by the Canadian Society for Chemical Engineering
in 2004. It can be accessed, and downloaded at no cost, at http://psm.chemeng.ca/
Products/OCM_Guidelines .

Types of organizational and personnel changes that can have a negative effect on
operational risk management, as lis(ed in this publication, follow:

• Reorganizing or reengineering
• Downsizing the workforce
• Attrition and aging of the workforce
• Outsourcing of critical services
• Changes that affect the competence or performance of other organizations

providing critical services under contract (e.g., equipment design, process control
software, hazard and risk assessment)

• Loss of skills, knowledge, or attitudes as a result of the above

Such changes, the authors say, are not as well addressed in applicable guidelines
as a,re changes ii) equipmynt, tools, work methods, and processes. The purpose of the
publication is to promote what is considered to be the appropriate d~msideration ..

I now give more emphasis to· the impact of organizational changes on operation~ nsk
management because incident ryports on some serious injuries and fatalities indicate
that a significant contributing factor was a reduction in staffi~g, as to both number

0
~

employees and talent level. As a result, unacceptable risk situations developed for such as.

• Inadequate maintenance
• Inadequate competency
• W~rkers being stressed beyond their mental and physical capabilities (tw0 persons

domg the work for which three had previously been assigned) .
• A person working alone in a high-hazard situationfor which the standard operaung

procedure calls for a work buddy

THE SIGNIFICANCE OF TRAINING 371

RISK ASSESSMENTS

Of the MOC examples require that risk assessments be made at several stages of some Th . . hi
the change activity. e mteThnt is ~okac eve and maintain acceptable risk levels
thfOughout the work proc~s. us, ns assessments are to be made as often as needed

changes occur and particularly when unexpected situations arise. In this regard,
~ety professionals who beco~e ~killed in making risk assessments can provide a
consultancy that demonstrates s1gruficant value added.

Appendix F, Risk Assessment, in Z 10 is a valuable resource. In addition, a recently
developed American National Standard is recommended as a reference on risk
assessment. ANSI/ASSE Z590.3 is titled Prevention through Design: Guidelines for
Addressing Occupational Hazards and Risks in Design and Redesign Processes.
This standard was approved by ANSI on September 1, 2011. Risk assessment is its
core. Its content is applicable to management of change whether the contemplated
change involves new desigris or redesign of existing operations. Of particular interest
should be the sections on:

• Relationships with Suppliers
• Safety Design Reviews
• The Hazard Analysis and Risk Assessment Process
• Hai.ard Analysis and Risk Assessment Techniques
• Hierarchy of Controls

RISK ASSESSMENT MATRICES

In Z590.3, the use of a risk assessment matrix in the risk assessment process is
strongly recommended. It is also emphasized that all involved ~n risk assessments
arrive at a common understanding of the meanings of the terms used in the matrix.
Severat examples of matrices are given in a 2590.3 addendum.
. An example of a matrix is available in Chapters 2 and 11. It was selected because 11

was preferred by operating employees who were brought intp the risk assessment
Process. They said that establishing a mental relationship between numbers such
as 6 and 12, first made it easier to understand the relation between terms such as Mocte · ‘ · rate Risk and Serious Risk.

THE SIGNIFICANCE OF TRAINING

1’o emphasize the significance of training in achieving a successful MOC system, ref-erence. S .~ 18
made again to the Guidelines for Management of Change for Process aJety.

1’rainin c • • t d g 10r all personnel is critical Many systems fatled or encoun ere severe ProbJe bee · 1
h . ms ause personnel did not understand why the system was necessary,
ow It Worked, and what their role was in the implementation. (p. 58) ,

372 MANAGEMENT OF CHANGE: SECTION 5.1.3 OF 210

The culture change necessary to put a successful MOC system in place cannot b
achieved without a training program that helps supervisors and workers understa :
the conc~pts to be appl~ed. ~ere the MOC system ~lates to many risk categori:s
( occupational, the pubhc, envrronmental, fire protection and business interruption
product quality and safety), the training provided must be more extensive. ‘

I would like to avoid the impression that training is not of great importance because
of th~ brevi~ of the comment_g made h~re on the subj~t. ~t i_s a near ~~solute certainty
that mstallatmn of MOC/pre-Job planrung systems will frul 1f the trrurung given is not
appropriate to the significance of the changes to be made.

DOCUMENTATION

The importance of maintaining a history of operational changes needs emphasis. It
is vital that all ,modifications be recorded in drawings, prints, and appropriate files.
They become the historical records that would be reviewed when changes are to be
made at a later date. Comments on changes made that were not recorded in drawings,
prints, and records are found too often in reports on incidents resulting in serious
consequences. Examples found in incident investigation reports of unrecorded
changes include the following:

• The system was rewired.
• A blank was put in the line.
• Control instruments were disconnected.
• Relief valves for higher pressures had been installed.
• Sewer line sensors to detect hazardous waste were removed.

ON THE MOC EXAMPLES

To display the substance and variety ·of the MOC systems that organizations have
in place, very little change was made in the examples that I received. They Va:’J
greatly in content and purpose. Some are contained in one page. Others require
several pages to cover the complexity of exposures and procedures. Some M~C
procedures have introductory statements on policy and ‘ procedure. Some don t.
Nevertheless, it is apparent that a MOC system need not necessarily have to meet
a theoretical ideal to provide value. th

Examples are to serve as references. It is highly re\:ommended that none 0 ~i;
examples be adopted as presented. A MOC system should be drafted in accord
an organization’s particular needs and its culture. , fthe

As each of the MOC examples was reviewed, it became apparent that some O rms
terms used in them were not readily understandable . But more than likely, the t~ded
are understood in the orga~zation µiat develope~ the MOC ~ystem. It w~s ~:Cly is
to leave those terms in the examples to emphasize ,that: whatever terrruno gage
included in a MOC procedure, the tei:m.’s ‘must be i,n concer,t with the la:tu all
commonly used within an organization; and the terms ‘must be understoo Y
who become involved in a MOC initiative.

<

ON THE MOC EXAMPLES 373

Four examples are included in this chapter as addenda. They are designated
MOC Examples 1, 3, 4, and 10, the designations given to them in the total of 10
MOC systems available.

Access to six other MOC systems, some of which cover several pages, can be
btained at www.asse.org/psextra. This is an American Society of Safety Engineers site

;or which open access is provided. An earlier and briefer version of this chapter was
published in the July 2012 issue of Professional Safety . Click on “Professional Safety
ExtraS,” scroll down to Archives, and go to July 2012. You can click on supplemental
material for my article and bring up 43 pages of MOC system examples.

Example 1: For An Operation Producing Mechanical Components
Toe Pre-Job Planning and Safety Analysis system shown in Example 1, a one-page
outline, was developed because of adverse occupational injury experience in work
that was often unusual or one-of-a-kind or required extensive and complicated main-
tenance activity. (Example 1 is an addendum to this chapter.) .

Its relative simplicity in relation to other examples will be obvious. But it was applied
successfully for its purposes. It would be well to note that safety professionals:

• Prepared the data necessary to convince management and shop floor personnel
to try the pre-job planning system they prl?posed

• Said that the training sessions held were highly significant in achieving success
• Emphasized that work situations discussed in the training sessions were real to

that organization
• Addressed the benefits for both productivity/efficiency and risk control in their

proposal and in the training sessions ,

For whoever initiates a MOC system, the procedure described in the following
will be of interest.

At a location where the serious injury experience was considered excessive for
non-routine work, safety professionals decided that something had to be done
about i~. As they _prepared a course of action and talked it up at all personnel levels,
from top management down to the worker level, they encountered the usual nega-
tives and push-back: e.g., it would be time consuming, µte workers would never
buy into the program, and the supervisors would resist the change. The safety pro-
fessionals considered the negatives as normal expressions of resistance to change.

Their program consisted, iri effect, of indoctrinating management and the
workforce in the benefits to be obtained by doing pre-reviews of jobs so that
lbe work could be done effectively and efficiently while, at the same time,
controlling the risks.

~ventually, management and the line workers agreed that classroom training
sessions could be held. Later the safety professionals said that the classroom
tr ‘ ‘ ‘ aining sessions and follow-up training were vital to their success.
. At the beginning of each of those sessions, a management representative
introduced the subject of Pre-Job Planning and Safety Analysis and discussed

I
L

MANAGEMENT OF CHANGE: SECTION 5.1.3 OF 210
374

reasons why the new procedure was being adopted. Statistics. on accident
perience prepared by safety professionals were a part of that mtroduction.

~en, safety professionals led a discussion of the _outline_ shown in MOC
Example J. It set forth the fundamentals of the pre-Job review sy~t~m being
proposed. After discussion of those pr~edures, a~endees were d1v1d~ into
groups to plan real-world scheduled maintenance Jobs that were descnbed in
scenarios that had previously been prepared.

At this location, supervisors took to the pre-job planning and safety analysis
system when they recognized that the system made their jobs easier, improved
productivity/efficiency, and reduced the risks. And they took ownership of the
system. As one of the safety Pr

· Note the requirements under the caption ‘Vpon Job Completion” in the Pre-Job
Planning and Safety Analysis Form. The detail of the requirements reflec~ particular
incidents with adverse results thai occurred over several years. It is recommended
that every MOC system include similar procedures to be followed before the work
can be considered completed.

Example 2: Specialty Construction Contractor
This Field Work Review and Haz.ard Analysis system is encompassed within twci pages.
It was provided by a safety professional ·employed by a specialty construction contractor
that has several crews active in various places at the same time. Note that the names of
employees on a job are to be recorded as having been briefed on the work to be done. The
checklist included in the form pertains to occupational, public, and environmental risks.

When asked what gave impetus to the development of the change procedure, the
safety professional responded “We learned from costly experience.” It was said that
the procedures required by the change system are now embedded in the company’s
operations and that it is believed that the procedure results in greater efficiency. It is
known that fewer costly incidents have occurred.

This example has a direct relation to the purposes of ANSI/ ASSE 10.1, a standard
for construction and demolition operations entitled Pre-Project & Pre-Task Safety
and Health Planning. This standard is an excellent resource for contractors and for
0:g~niz~tions that establish requirements contractors on their premises. Note tbe
d1stmc11,ons: Pre-Project Planning and Pre-Task Planning.

Example 3: Form for An Operation That Has Had
Serious Injury Experience ,
Thi ‘ th s Pre-T~kAn~ysis form makes much of obtaining required permits and of assuring
::;u:_ervisors bnef emp!oyees on the order of activities and of the risks to be encoun-

h
te · mploye<:s are requrred to place their signatures on the form indicating tha

t
tbeY

ave been so bnefed Thi · th ‘ Jedge b th . . · s is e only example requiring employees to ackn°W ‘
Y e;r signatures, !hat they have been informed about hazards and risks prior to tbe

start o work. (Example 3 is an addendum to this chapter.)

ON TH E MOC EXAMPLES 375

example 4: Paper Setting Forth a Management
p0IICY and Procedure
This is a basic guidanc_e paper on MOC concepts and procedures, conde nsed to three
ages It is a composite of several MOC policies and procedures · 1 • d p . . . . . 10 p ace iss ue

by organizauons 10 which o~,eratlons_ were not highl y complex. Reference is made
in this example to a M<;>

example 5: MOC System With a Specifically Defined
pre-Screening Questionnaire

This MOC system, in three pages, begins with an interesting pre-screening ques-
tionnaire. If the answer is “No” to all the questions asked, the formal management
of change checklist and approval form need not be completed for the work being
proposed. The question often arises in discussions of management of change systems:
To what work does the system apply? 1bis organization developed a way to answer
that question for its own operations.

Example 6: High-Risk Multiproduct Manufacturing Operation
This Management of Change Policy and Procedure reflects the high hazard levels
in the organization. Captions in this four-page system are safety; ergonomics;
occupational health; radiation control; security/property loss prevention; clean air
regulations; spill prevertion and community planning; clean water regulations ;
solid and hazard waste regulations; environmental, safety, and health management
systems; and an action item tracking instrument. The following appears in the
procedure paper announcing the system:

If a significant change occurs with respect to key safety and health or environ-
mental personnel, the matter will be reviewed by the S&H Manager and the
Environmental Manager and a joint report including a risk assessment and
their recommendations will be submitted to location manag~ment.

Example 7: Food Company
This four-page Management of Change policy includes produc~ safet_y and_ pr~uct
quality among the subjects to be considered . Detail on the su~Jects hsted !s highly
techni~al and extensive. The safety director at this loc~tio_n _10formed t~s author
that discipline in the application of this MOC system 1s ng1d a_nd that It reflects
management’s determination to avoid damaging incidents affect.mg personnel and
the environment and variations in product quality and taste. Provisions for pre-StartuP
and post-modification are extensive. A risk assessment is to be made after changes
are made and prior to startup.

376 MANAGEMENT OF CHANGE: SECTION 5.1.3 OF Z10

Example 8: A Conglomerate

Iota Corporation bas a five-page management of change procedure outlined in four
sections. It is worthy of review.

Section I requires completion of a Change Request and Tracking System Requirements
form in which the change is described, a tracking number is assigned, and approval levels
are estab~sbed. Approval levels are numerable, including headquarters in some instances.

Section II outlines a Change Review and Approval Procedure that is extensive
with respect to occupational safety and health and environmental concerns.

Section ill is a Pre-Implementation Action Summary Form which lists subjects for
which actions are necessary before work on the change can be begun, and the persons
responsible for those actions.

Section IV lists 11 points in a Post Completion Form.

Example 9: An Extensive MOC System for a Partlcular Operation
Reading this Management of Change standard is recommended for educational
purposes because of its structure and its content. It is somewhat different in relation
to the other examples. In its seven pages:

• Requirements for technical changes and organizational changes are dealt with
separately and extensively.

• Much is made about organizational changes for which risk assessments are required.
• Technical changes to which the standard applies are outlined in detail.
• Risk assessment is a separately listed item pertaining to all operations.
• After a lengthy discussion of general considerations, requirements for a six-point

management of change standard are outlined. They are: Management Process;
Capability; Change Identification; Risk Management; The Change Plan; and
Documentation. Each of these subjects is discussed thoroughly.

This is a concept and procedural paper. It does not include the forms used to imple-
ment the procedures.

Example 10: An International Multloperatlonal Entity

Application of this MOC system, a Management of Change Policy for Safet_y and
Environmental Risks, extends the activities of safety and environmental professionals
beyond that of any other example. It is an informative read. The example shown here
covers 10 pages. (Example 10 is an addendum to this chapter.) The bulletin, issued by
the Safety and Industrial Hygiene entity within the organization, is much longer th.~
is shown here. All exhi~its could not be made available for proprietary reasons. Bne
comments follow on the unique aspects of this MOC system.

D D ·1 · · · J · • nmental • ue 1 1gence 1s me uded m a list of Definitions. Safety and env1ro ·
professionals are to assess acquisitions et al.

REFERENCES 377

, Global franchise Management B?ard M~mbers are listed under “Responsi-
bilities.” They are to ensure comphance with the standard.

, A Preliminary Environmental, Safety & Health Assessment Questionnaire shall
be initiated during the project planning stage.

, Under a Section titled Evaluating Change (Risk Assessment Guidelines) these
subjects are included, which may not be included in other examples, at least not
as extensively:
, New Process Product and Development
, Capital Non-Capital Project
, External Manufacturing
, Business acquisitions
, Significant Downsizing/Hiring

, Conducting Risk Analyses is a major section.

This is a noteworthy MOC system because of its breadth. It is interesting that the
system was issued by the Safety & Industrial Hygiene unit. That implies management
support for personnel in that unit and superior operational risk management.

CONCLUSION

It is the intent of this chapter to provide a primer that can serve as a base from which
a MOC system suitable for a particular entity can be crafted. I recommend that safety
professionals consider whether the organizations to which they give counsel could
benefit from having MOC systems within their overall Operational Risk Management
Systems. Having such a system in place for changes that should be pre-studied because
of their inherent hazards and risks and which may affect the safety, productivity, and
environmental controls is good risk management.

REFERENCES

A Mana?ers Guide to Implementing and Improving Management of Change Systems.
~ashi?gton, DC: Chemical Manufacturers Association (now known as the American

hemistry Council), 1983.
ANSI/AIHA 210 . . . M -2012. Amencan National Standard, Occupational Health and Safety

. anagement Systems. Fairfax, VA: American Industrial Hygiene Association, 2012. ASSE
is now the se · · • ANS cretanat. Available at https://www.asse.org/cartpage.php?link=z 10_2005.
/A~Q Q900l-2000. Quality Management Systems-Requirements Milwaukee, WI:

mencan Society for Quality 2000
A.Nsu • ·

H ASSEZS90.3-20l 1. Prevention Through Design: Guidelines for Addressing Occupational
s; ~rt/Es an_d Risks in Design and Redesign Processes. Des Plaines, IL: American Society of
. e Y ng10eers, 20 I I.

Aviation G . .
round Ope ra11ons Safety Handbook, 6th ed. Itasca, IL, Nauonal Safety Council. 2007.

‘ –

378 MANAGEMENT OF CHANGE: SECTION 5.1.3 OF 210

Guidelines for Management of Change for Process Safety. Hoboken, NJ: A joint public .
of the Center for Chemical Process Safety of the American Institute of Chemical Engin ation
(New York) and John Wiley & Sons (Hoboken, NJ), 2008. eers

Guidelines fo r Technical Management of Process Safety. New York: Center for Chemical
Process Safety, I 989.

Johnson, William. MORT Safety Assurance Systems. Itasca, IL: National Safety Council
1980. (Also published by Marcel Dekker, New York.) ‘

Managing the Health and Safety Impacts of Organi;:ational Changes. Ottawa, Canada·
Canadian Society of Chemical Engineering, 2004. Accessible at http://psm.chemeng.c~
Products/OCM_Guidelines .

OSHA ‘s Rule/or Process Safety Management of Highly Ha;:ardous Chemicals. 29 CFR 1910.119.
Washington, DC: U.S. Department of Labor, 1992.

OSHA’s Voluntary Protection Program (VPP). Section C. in CSP 03-01-002-TED 8.4, Voluntary
Protection Programs (VPP): Policies and Procedures, 2003 . At http://www.oshagov/pls/
oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=2976.

ANSUASSE AI0. 1-201 I. Construction and Demolition Operations: Pre-Project & Pre-Task
Safety and Health Planning. Des Plaines, IL: American Society of Safety Engineers, 201 I.

Safety & Health Management System eTool-Worksite Analysis. U .S. Department of Labor,
OSHA, at http://www.osha.gov/SLTC/etools/safetyhealth/comp2.htrn1.

Stephens, Richard A . System Safety Jorthe 21st Century. Hoboken, NJ: Wiley, 2004. (This is an
updated version of System Safety 2000, by Joe Stephenson.)

ct1APTER 18 .

LEAN CONCEPTS-EMPHASIZING.
THE pESI_G~ PROCESS:
SECTION’ 5.1.3 OF 210

Colleagues who are much involved in lean concepts were asked if they’ had experience
with their being applied in the original.design process.’The answer was ·no. Surely,
there is such activity, but I have located only one initiative in; which lean-and safety,
environmental, and health-considerations were integrated .into the design;ptocess.

Even though applying lean concepts to eliminate waste, improve efficiency, and
lower production costs has become popular l;}t the senior management level, it seems
that most of the initiatives relate to redesigning existing systems and work methods.
Nevertheless, that activity is a match for the provision in ZlO in Section 5.1 :3, whereby
management is to have processes in place “to prevent or otherwise control hazards in
the design and redesign stages.’!· · · ·

Safety professionals lia:ve opportunities· tb make contributions to operational
results as they tactfully bufforcefully bring ‘to mariag~rilenf’s attention that: ·

. . :

• An element of waste I that ‘Should be :addressed in the lean· process is the waste
arising from the direct and ancillary costs of accidents.

• As is the case with hazards and their accompanying risks, operational waste can
be most economically and effectively avoided in the design process.

llle~educing waste is the base on which the lean concept is built. Simply stated, lean
s creating . In a lean venture, activ’t• more value for customers with fever resources. . . . 1 ies orpr ‘ roductive time ocesses that consume resources, add cost, or reqmre unp

. . ‘

‘

©Ccond Editi ty Management: Focusing on Zl O and Serious lnJury Prevention,

201

4

John ;t-ed A Manuele. : .
ey & Sons, Inc. Published 2014 by John Wiley & Sons, Inc.

341

l ,

–
I II 1.• ‘ I ti

I

342 LEAN CONCEPTs-EMPHASIZING THE DESIGN PROCESS: SECTION 5.1.3 OF 210

without creating value are eliminated. Direct accident costs are substantial, and th
costs are a form of waste. Ancillary accident costs, such as those deriving from . ose
ruption of work, facility. and equipment repair, idle time of workers, traini~nter.

· · d rt t’ . g of replacements, and investigation an repo prepara 100 time, may represent
amount of waste equal to or greater than the direct costs. For incidents resulting ~n
serious injury, particularly when property damage and business interruption ~:
extensive, the ancillary cost and accompanying waste can be substantial.

To encourage safety professionals to seek meaningful involvement in lean initiatives
in this chapter we: ‘

• Comment on the absence of recognition in the literature that accidents produce
waste and that their outcomes are a form of waste to be eliminated

• Discuss the origin of lean concepts and how broadly they are being applied
• List definitions pertinent to lean and relate them to injury and illness prevention
• Discuss a successful merging ofleail, safety, health, and environmental concepts

into a design process
• Illustrate how the 5S concept is foundational in a lean application and how

hazards and risks are reduced through 5S applications
• Comment on lean.imple~entations in which hazards and risks were not addressed,

the result being greater risks of injury and illness
• Discuss a major educational work
• Provide a simplified model of a value stream map that recognizes hazards and

waste potential

ON THE LEAN LITER_ATURE

There is pienty to read r~garding lean; but there is a dearth of information in the liter-
ature on how the waste deriving from accidents should be addressed. It is a rarity when
consultants who advertise their l~an capabilities include the outcome of accidents as a

· · · pular form of waste. An example of that scarcity is demonstrated in one of moSt po Thi
books on le~, Lean Thinking, written by James P. Womack and Daniel T. Jonesdred:
excerpt is taken from the bo0k’s J·acket: ”This book has been sold in the bun an

. . · • . · · what of thousands of copies m a dozen countries.” How good 1s the book? ~s is
executive who managed a process that adopted lean concepts says about it:

Whil Th • ki g remains e there are many good books about lean techniques, Lean m n ·t,es the
one of the best sources to understand “what is lean” because it des~n in the
thought process, the overarching key principles that must be used as guides ·any.]

1. · f 1 nfidentl app 1cation o ean techniques and tools. [Comments made to me co
. f onned that

Nevertheless, the many readers of Lean Thinking would not be 10 te to be
the outcomes of accidents are to be included in a list of the forms of was
reduced.

ORIGIN OF THE LEAN CONCEPT 343

&’nir}y recent publication that I recommend highly can be of But a 1″” th great value to
t rofessionals and o er manag~ment personnel. It is unique. Robert B. Hafe

safe Y Pthorof Lean Safety: Transforming Your Safety Culture with Lean .,, Y
· theau fi b ‘Id h’ . management
is . bed in 2010. Ha ey UI s is case m support of the interconnection of I d,
P
ubliS • . ean an

“‘-‘ID 40-plus years m vanous management roles in manufacturing .~ safety uv d’ , none o,
which was as a safety di~ector. . b k .

‘[his is a di~erent mterestmg oo m that it gives guidance, from an operations
management v1ewpomt, on how to _make progress toward achieving a world-class
safety manag~ment system by a~p~ymg lean ~on~ept,s. Hafey emphasizes that safety

st be considered as a value within an organization s culture to achieve world-class
!Il~ormance. He makes it clear that to eliminate waste and to improve safety the
rocus at all operations levels has to be on improving the work process. He writes’:

The Key to understartding·this lean leadership style is the acceptance of the fact
that the process is the problem, not the person. (p. 19)

The book contains a large number of practical examples about process improve-
ment for lean and safety. It also contains many lean and safety forms. Thus, this is as
much a how-to book as it is a concept book. Throughout the book, Hafey promotes the
five-why system for solving problems of every type, including accident investigation:
In applying tlie five-why system, users ask why sequenti.ally until the problem’s real
causal factors are identified.

This is a valuable book for safety professionals who want to become familiar with
lean basics so as to be able to give· guidance as a contributor on a lean process team.
It is a book of fundamentals and is not as complex as other texts on lean with which
I am familiar. It is a good investment for continuing education. It is unique.

Progressive safety professionals will recognize this shortcoming-the non-recognition
of accidents as a source ·of waste by the appliers of lean concepts-as an opportunity to
educate all levels of inanagement on the advantage of including safety considerations
as the lean process is applied.

‘

ORIGIN OF THE LEAN CONCEPT

In much of the fiterature on lean Taiichi Ohno is recognized as the originator of
the lea , 1 ‘ b hi bl n concept about 50 y· ears ago while at Toyota; and Toyota has een a g Y
successful’ · · · · d · h l’t t re
t apphet of the concept But occasionally reference 1s ma em t e

1 era u
0 con · ‘ h t d th firscepts utilized early in the twentieth century by Henry Ford, w O crea e
sc~enti t “lean” auto production line; to Frank Bunker Gilbreth, who was a propo~e~t of
contr

1
6c management and motion:•study· to Walter Shewhart, a pioneer in stat1St1cal

0 ; and t w ‘ . d for his work on qualit O • Edwards Deming, who achieved worl renown
y management

Whatever th . ·. th tr e for operational
excene e ongms of lean the leaders at Toyota-as ey s ov . t

nce-.c · .• • ‘ . Ii · tion concepts m 0
What is Call omb1~~d, refined, and converted thelf waste e mma

ed lean ID the United States. .

MPHASIZING THE DESIGN PROCESS: SECTION 6 1
344 LEAN coNCEPTS-E . . 3 OF 210

SARE BROADLY APPLICAB.LE_
LEAN CONCEPT –

. . . literature on lean concepts des~ribes a~plications in m&n
While the ongmal been adopted to reduce waste m a vanety of sitµations ufacturing
the con~epts have larg” spectrum of service businesses, transportatio ‘ such as fo;

un
ung systems, a .., .1. . (‘ 1 di . , n ~omp . acco u·on health care fac1 1t1es me u ng em1ties as sn, 11 an1e8 h sing constroc , ~\a as , ware ou ‘ . ) product quality improvement, and environmental m &roup

h · ciao pracuces , · . anage P ysi
1
. . te non-value-added e-mails. How broadly have le~ cone · lllent,

and to e muna ,, . h • b . epts b
I ed

. ? E tering “lean concepts mto a searc engme nngs up ov~r 13 OOo een
emp oy • n , ,O(X)
references. · . · h h · . Safety professionals, particularly those w o . ave environmental managemen

s ‘bilities may want to look into the .EPA entry on the Internet entitled Le · t
respon I ‘ . . th Ti. lk’ . . d ” an and
E

•ronment Toolki.t. A major section m e oo it is captlone How to Incorp nv, S M . ,, Th orate
Environmental Considerations into Value tream appmg. -. e methodology shown
is the same as would be utilized fqr all aspects of safety. 1

DEFINITIONS

Understandably, several terips as,sociated with the lean concept .we Japanese.
Abbreviated definitions of those terms follow as they are applied in the design
process discussed later in the chapter, as well as some other d~fiqitions that are
used. This list.is somewhat.lengthy, intentionally. I~ reality, safety. professionals
need to be familiar with tl;le t_erms used in the organizations to which they give
counsel, and their meanings. TQey would pi:Qbably not need tQ pe thoroughly
familiar with all of th~ terms in this list.

‘ , • 1 .’ •

Flow, as a goal in the le_an process, is achieved after w~t~-is.~emoved frqm the
system and tpe improved process (value litream) J.Jlns s,moothly ~d efficiently
with very little waste in the work of personnel or in equipment downtime.

Jidoka refers specifically to machines or the production line itself being able to
st0P automatically in abnormal conditions (e.g., when one machine breaks
down,_ when heat rises beyond a set limit).· Jidoka applipatioqs do not allow
d~fec~ve parts or products to go from one workstation to another.

· ~• m lapjlllese mearu: “change f.or the. better”. In ,\m~can ?~ish, tfie ‘t
co~e to mean con9nual improvement. For the pu,:pose of tbi.s ,cbapter,

ez;nph~is in applying the continual imp
1

rovement process is to e,~minate waste,
Jlleamng those f · · , · ‘ ‘ · Muda. ac ivities that add to costs but do not provide .value. ot

encompasses all acti ‘ti th . , full therefore n addin val S vi es , at consu~e resourc.~s .w~t~ Y, . tinual
reduc! ue. even type~ of waste were idqntified at Toyota for which con

.on was to be obtained. .

The Seven Wa,ftes
Defects in prodµc~ . , , . • · consu(lle

mate·n·a1 and’ : or servic;es are obviously wasteful in. that ,theY
require dd’ · ‘ a Itional production and correction tim~-

• • • • I

DEFINITIONS 345

. . the excess production or acquisition of items beyond what is
d,,cuon is · dd’ · al · al · overf’ro .. d d. Where overproduction occurs, a 1tion cap1t mvestment

actuallY nee e d costs are increased without adding value since more storage
is necess1~=erial ban,dling are necessary. Overproducµon that results in
space :1° terial handling adds to risks.
e1’cessrve _ma wastes are those that require additional, and .unproductive moving

rransporlatio~ in p~ess. Each time a product is moved there is added risk of
of a produ~e product, equipment, and facilities, and harm to personnel. In the
daJllage to ocess the product fills valuable space and requires time expenditures
!lloving pr ‘

. ut adding value. . , . .
~•~0 fers to botp the unproductive time spent by workers waitjn.g , for

waiting.: or components in a process to arrive and the time required for exces~
Illaten tion to flow through the system. An additional example is material or
~:::ation waiting to be worked on to complete a customer order. Similar
~:tes occur when incidents happen that could result in injury or damage to

property. – f h · d d . addi . ‘al ‘tal l ntory buildup in excess o w at 1s nee e requires an · tion cap1
nv:tlay and produces waste because of the need for additi~nal storage space and
~andling time. Frequent handling of the inventory adds to the risk of injury.

Motion refers to worker unproductive time and movement where the process is
cumbersome, inefficient, and wasteful. This implies that the process may also
be hazardous. · · ·

Overprocessing means ‘using a · more expensive or otherwise valuable resource
than is needed for the task. Ove’rprocessing also inclu<;tes costly rework.

Poka yoke means “mistake-proofing” or “fool-proofing’\ the purpose being to
design work and processes so that it is nearly impossible for people to make
mistakes. An example is designing hose connections or electrical connections
so that they can be put together in one way only, thereby reducing risk. This
is an important but often ·neglected con~ept with respect to employee and
product safety.

Mura pertains to unevenness in the work flow: The goal is steady work flow.
Muri relates to avoiding overburdening equipment’ or employees: The goal is to

·reduce the workload to acceptable levels. For equipment, that might mean
operating at 80% of the maximum specified limit ·For employees, designihg work
method· tH · P ll s at are overly stressful and working excessive hours are to be avoided.

defines · the operational situation after which much has been accomplished
1tnh a~plying the lean process and inventories can be ‘ maintained in relation to

e pull” prod . . as represented by customer orders. Waste from having excessive
(e.g. u: in inventory, and all that implies, is to be as low as reasonably practicable
risk ~f ~:~t of excess space, the financ~Qg ,of the ~xc~ss inventory, the cost and

Total p ~on?,l handling .of inv~ntory). ,
roductive M • · , is always abl . amtenance_ i~ to assure th11t all equipment used in a process

be interru e to perform its tasks so that production or work processes will not
pted. ·

\.

l ‘•

346
~ONCEPTS-EMPHASIZING THE DESIGN PROCESS: SECTION 5 1 LEAN · .3 OF z:10

MERGING LEAN AND DESIGN CONCEPTS . ·. , _
J

The One
exception with which I have become familiar, in which lean

d · h · · · I d · ‘ Safety
rro
• nmental concerns were merge mto t e ongma es1gn proces . , and env . . . t .. s, 1nvo1

pharmaceutical company. For a maJor proJec ‘ new equ1p1?ent was to b Ves a

d
installed ‘in an existing facility. In lean language, that would be a “be acquired an . . d . . . rownfi

P
lication. In a “greenfield” appbcation, es1gn engmeers mcorporate le eld” ap . ‘li an cone

into the design of an entirely new 1ac1 ty. . . ep~
What this pharmaceutical company has done 1s an excellent example of h

and safety can be addressed in the design process concurrently. This is ow_ lean
imaginative, and creative methodology. In_ a discussion with the senior e>:ec:a::’
managed this project, he made the followmg comments. ho

Often within an organization there are separate Quality, EHS and Operational
Excellence/Lean functions. Each of these functions has its own distinct vocabu-
lary, metrics, and evaluatiop processes and procedures. Viewed from ~ve, the
purpose, motivation, and objectives of these fupctions have considerable overlap:
Do it once; do it safely; do it with quality; do it cost-effectively.

Responsibility for the overall management and delivery oJ a Design/Capital
project is usually in tpe Operations function. Past pr,actic~ often has been for
Operations to interface with Quality, EHS and Lean functions separately. This
creates a signj.ficant. redundancy of effo~ and can raise the risk of an issue
“falling in the cracks’~ between these functions.

In a lean application, it was decided to gather all of the functions and construct
a Value Stream Map covering the entire project. This creates a ”visual” map of
the project from begiqning to end. It aIIows a clear identification, of functions and
who is responsible and accounijlbJe for ~h step of tpe project. It identifies

. opportunities to perform tasks in such a way that all of the oversight and approval
criteria qf each function are satisfied simultaneously.

A cross-functional integrated risk assessment tool was developed. Our theme
w~Do it once: Do it right. If this cross-functional team is created and managed
properly, the expected communication and responsibility requirements (ll”e clearly
established. If the team is well managed, the r~ult is significant cross-functional
cooperation and excellent results.

Lean ·requires fr<;mt-line operator participation. Significant valuable input and b~y-in can be achieveq with their ~ctive participation in the project. nt

Lean terminology was the base language for the managementandmeasureme
of the proj~t. [From my nqtes].,

N . –~ 1 operations personnel at this pharmaceutical location have had Jean traI tic~
~~breviated version of this company’s process follows. It is close to ‘the

th
~ref the

ideal: S~ety professionals can learn from it. But first, the relationship to Zl
0

lean-design process is shown:

‘f~BLE 18.1
~ioninZlO

Risk assessments
t{ierarchY of controls
oesign reviews
Management of ch~ge
Pr<>Curement

r10NTOZ10
REI.A

THE COMPANY’S LEAN-DESIGN PROCESS

Section Designation

5.1.1
5.1.2
5.1.3
5.1.3
5.1.4 ‘

f z10 were prudent when they said in E.1.3 that:
‘j11e writers o

347

. tandard is designed so it can be integrated with quality, environmental,
‘Jb!S sth r managem.ent systems within an organization.
andoe . .

h integration would enhance the probability of a lean process being highly 50
\ful That was done in the case being discussed. This ·company’s initiative ,is

succes . • h . . al f th . . . . Jarly noteworthy mt at 1t mcorporates sever o e prov1S1ons m ZlO. Those partJCU . ,
provisions are ~oted in Table 18.1. ‘ . · .

I

CRITERIA FOR APPLYING THE LEAN-DESIGN PROCESS

Use of this c6nipany’s Lean-Design process begins when an assumption is made that
a project is of such magnitude that it will require following the steps outlined in its
Request for Capital Expenditure Procedure. For purch~ses below the capital expen-
diture request level, the basics in the process are applied, but not as extensively.

For example, if the machine shop supervisor put through a request to purchase a
metal-cutting saw:

• Safety considerations would be established and they would be reviewed by
environmental, health, and safety professionals as ·well as by more than one
level of IIianageinent.’ · · ‘

• Those safety requirements wo~ld be included in the·p~chase b~der.
• After receipt and installation of the equipment, a safety validatioi:i would be made.

THE COMPANY’S LEAN-DESIGN PROCESS
•I , ‘

The Concept Stag~
Fro ,. • ‘ • · · a er::: so~rce-research and development, ‘engineering, any operations department,

nctionaI group, maintenance, individual workers-an idea may be proposed

l!I

348 LEAN CONCEPTS-EMPHASIZING THE DESIGN PROCESS: secr,o
N 6.1,3 0 1′., … ,o

for process improvement: A broad range of brainstorming b~ a teazn
it is concluded . that the idea. sh~ul~ be moved forwar~ ~d the ex. tak~s Place
requires followmg the orgamzation s Request for Capital Ex.pe d’ Penditure 1 · Ir · al · ht t · n Iture t>- eve1 a review and tentative approv 1s soug a a semor management 1 .–roced · · d eve1 A lire manager 1s ass1gne . · · · ” ProJec;

capital Expenditure Request and Element Champion R~vla
– . W

The Capital Expenditure Request would describe the design obiectiv
. fi . d J es of the generally, make the busmess case or 1t, an request the necessary fu d’ ProJect

company, each of the 26 elements in its safety management system i n 1~g. In this
Champion, most often som~one at an upper.management level. s as&igned tci a

For example, the chief executive assumes direction and accomplishm ‘ .
bility for two of thqse elements; four are assigned to another senior ment rf:esponsJ.

. . anu acturi
executive. At this stage, all of ~e safety management system element cham ‘· , ng
become aware of the project, and a sign-off 1s required by e~ch of them. pions have

Identify the Customers/Users
In this context customer or user is every employee who may be affect~~ py the revi-
sion in a process being proposed. It really means everyone. The purpose is to assure
that all persons who could be affected are aware of the process change proposed
and can provide input as ,~e. ~ctiv,~ty.proceeds. I~~ntifyiqg th,_e c.~~tmpers and users
is considered a very important step in the lean process. · · ·

With respect to external cµstomers, the char89teristics of the produc;lS µianufactlµ’ed
have been agreed upon, close estima,tes are made pf the p~oduct amounts that will be

• . I, •
purchased and over what time spans, inventories are kept 1,1nder tight control, and the
delivery methods and times of delivery are arranged. · · ‘ ·

‘ . ,:. . .

Project Customers/Users Requirement Specification
At this point a senior-level m a,yager prepares a document. expandin~. on the origin~
idea. The document contains enough detail to specify the outcomes ~xpected, an_
some criteria are established. Customer~ and u’sers (empJoyee&Y may submit tbelf
specifications and their suggestions on how w~te can be eliminated.

‘ ‘ ‘ ..

Value Stream
1

Map
A al tr . ted thi . Thi . Ii . flowchart that includes v ue s earn map 1s cr~a at _ s _poi?~· , ~-1,s a pr~ , ?11nary . _. , • rial receipt
every step of the production process’ as corfceived at this time, from raw mate esses 10
to product going out the door. It is an important step in that it documents 1?~-~roc ry steP
be considered in the waste elimination initiative. The value stre’am includes eve
in a _pr~es~ t9 produc~ pr~quct Of 1proyi~e a sezyic~. 1 • id~s an 0ppor·
. :VaI1,1e streruµ 11}-appipi is c1; vitaj s~p.jn the lean qoncept,, in that It PfO.V AddenduJJI A

turuty for team brainstorming to identify activities that do not add value.

THE COMPANY’S L
EAN-DESIGN PROCESS 349

. chapter describes “A Simplified Initial Value Stream ,,
iJ1 t!U5 streSJ11 mapping to: Map · Lean practitioners
ose vatue

d n.:r., major sources of non-value-added time in al • I e ui1 a v ue stream
, Envision a less wasteful ~ture state. ·

D .,elop an implementatlon plan for future lean act· .. , e• , 1v1ties.

proJect conceptual Design
that preceded this step in the process influences the draftin of the .

;Jl_gn It shows the layout proposed, and building and util~ty . proJectconceptual
desI · • · . i impacts, and contains
specifics on the maJor eqmpment needed. Environmental health d afi .
n·ons are addressed in this concept stage. All of the foliowing pe, anrs s elty c~nsider-a d • . . . onne review and
. n off on the concept es1gn. operation executives· subiect tt . . s1g afi . . • ma er experts; envrron-

01ental, health, and s ety professionals; engmeers; maintenance personnel; and the
t,ui!ding manager. ·

Since I knew that management did not rely entirely on the drawm· th t . . gs a came out
of the CAD (computer-aided d~sign) system as the sources in the development of
operating procedures, the executive who managed the process·was asked ho h . Thi . h h . w e came
10 that conclusion. s 1s w at e said.

One of the shortcomings of CAD/Computer design and printed blueprints is
that they do not allow for full real-life visualization of the process in actual
physical/hu~an terms. The creation of physical mock-ups of key components
of the plant, particularly where critical operator interface is involved, can greatly
improve the design. .

A physical mock-up will allow line-of-sight, ergonomic, safety, simplicity
of maintenance, and lean productivity issues tci be identified that otherwise
would be missed by relying on computer-generated designs. It is important to
understand that people may have difficulty visualizing a computer-based design
in real life.

Mock-ups can be constructed out of plywood or cardboard for relatively
little cost. They allow the actual plant operators to see and feel the critical steps
of the process and apply lean concepts to the development of work instructions
for each step of the process. Mock-ups allow for front-line input and participa-
tion. Our experience was that many lean and safety improvements came from
suggestions made by operators as tliey worked in the simulated mock-ups. That
Participation creates a significant and valuable “buy-in.” .

Experience has shown that without exception, a Il!ock-up will re~eal a
number of critical issues that otherwise would have been missed in the design
process when using CAD as the only means of illustration. F~r_ther, mock-ups
allow for the ·development of lean work practices and trairung procedures
Parallel to the actual building and installation of the plant and speeds the ~tartup
and debugging process significantly. [From my notes] :

4

350 LEAN CONCEPTS-EMPHASIZING THE DESIGN PROCESS: secr10
N s.1.ao”.,

<.1Q Change Control Provisions This company operates under the regulations of several go Therefore a rigid change control system is in place to assure thvetl'llrnenta1 .. .

‘ . . a all . “ntir and environmental requirements are met. At a semor managem quality
8

1es,
. . I ent lev l ‘ afet control document is produced requmng approva by all dep~rt- e , a ch Y,

I. . . I – …. ,ent he~-1 an. point, the head of the c9mp tance group, ts partt~u arly interested in s -:us, i\.t
1
~e

regulations are met. In 210, the comparable requirement is to hav eeing that~s
. . 513 earn¾ change process m place: Section . . . agernentor

Project Safety Clearance and Lean Review
This is a summation step wi~ .respect to all of the foregojng. The desi n · ·
is reviewed by the environme~tal, health, and safety group and by th g d0culllen1
group. Determinations are made with respect to the need for furthers e£ compliance
in individual p~eces of the process or because of their interrelation:~ty analysis
specifications are expanded and become more specific. ps. Safety

Although lean considerations hilVe been a part of this process from the b . .
applying lean concepts is stressed mQre rigorously here by the proiect emginIUng,
Th . fi 1· . . h J anager e purpose ts error-proo ng, w~ste e rmmatton, to ave the process stop wh th ·
equipment recognizes a fault, and to avoid rejects. All or some of the leans/~ e
mentioned previously-Poka Yoke, Jidoka, Kaizen, or Muda-may be broug:t i ~s
play, but the Muda concepts prevail throughout. Waste is to be as low as reasona~l;
practicable.

Also, since this company has been a meticulous applier of the SS system (defined
in their usage as – Sorting, Simplific~tion, Systematic Cleaning, Standardization,
and Sustairung), the 5S system concepts are overriding in the lean ‘process. It was
said by a senior executive at this location that “If the staff has not been educated in
5S c~ncep~s and belie~~ that their substance is ~o~e value, ··y~u can forget about
lean. You must have established a stable environment in which waste elimination is

! i • ‘

a fundamental to _move into ~e next step .:to ~cc.omplish lean.”

Drafting Vendor Specifications
Engineering persQnnel draft vendor ~pecifications. Manufacturing, environmental,
health, and safety, and operating personnel may ,also -be involved. At this staget:~
munication begins with a selected vendor. Subject matt~r experts employed Y
vendor may assist in.drafting specifications for the project.

Conceptual Design Risk Assessment
1 . rn~ . . . k assess

This review takes place at the concept and drawing level. Formal ns ments are
methods, qualitative or quantitative are used as required. The ri~k asse~sonmen1al.
d • . h the env1r ocumented and approved by a multifunctional team; of whic
health, and safety personnel are a part. ,

THE COMPANY’S LEAN-DESIGN PROCESS 351

d nt reviewer, not a part of the project team, must also sign off on the
Afl indepen e Several people at this location have been trained to do Failure Mode

essJllents.
os1′ ass Analyses.
g11d sff eets

11rn1narv Design
1’11

8 pre mbers work with the vendor to assure that the users’ requirements are
project te:::ables from the vendor inclu~e schematics, flow diagrams, drawings,
(!let. ‘fhe onent specifications, and operatmg procedures and training manuals.
further coJllP ,

Stream Map: Waste Scavenger Hunt (Muda Check)
va1ue

tream map was created when the project was in the concept stage. At this
A value \ntal phase, an additional flowchart is made to depict the design proposed. As
developm viously Muda encompasses all activity that wastefully consumes resources stated pre ‘

does not add value.
butA Muda check takes place ~s a waste _scavenger hunt t? fu~er reduc~ _pr~uct

& 1 possibilities, overproduction, excessive product handling, idl~ and waitmg time de1ec 1 . . d hi ffi . . . perating personne , excessive mventory, an to ac eve e ciency m processmg
:do the best probable use of employee skills. All personnel levels are involved.

Proposed Design Safety/Risk Assessment: Create System Drawings
Now that a proposed design is available, additional risk assessments as needed are made,
prior to building the system. The environmental, health, and safety staff is prominently
active in the risk assessments, along with other involved personnel. Use of formal risk
assessment methods is more frequent at this stage. A final sign-off by the independent
reviewer is necessary.

At this point, the design is frozen, the vendor creates system drawings, and the
vendor builds to drawings.

Safety, Operational and Lean Review

At the vendor’s location, before the equipment.can be shipped, the purchaser’s envi-
ronmental, health, and safety personnel assure that all safety-related specifications
have been met. . . ,

~actory acceptance testing takes place at the vender’s location and members of the
::iew ~eam (engineering, operations, maintenance, validation, et al_. ) determine that

~U!~ment operates as expected and that waste is as low as reasonably practicable.
Staffh sis a large part of the approval process prior to shipment of the equipment. The
h as found that testing at the vendor’s location has avoided many issues that would avetober 1

R . eso ved later on their shop floor. . ·
ev1ew by mai t . . h . . ff a th com , . . n enance is espec1:ally important here, as t err .sign-o auects e

the tty s ability to apply a Total Preventive Maintenance initiative. With approval,
uipment may•be shipped to the purchaser.

LEAH CONCEPTS-EMPHASIZING THE DES/ON PAOcE
ss: sec,,oN

352

S.130 Standard Operating Procedures . · “2:10
In reality, this function is done in parallel with the prev·

. d d l . . ious step standard operatmg proce ures, eve opmg training modul s. It inv
needs, drafting production records, and so on. es, defining re01Ves wtit·

col’d L tng

Faclllty Review and Approval

After installation, with which the vendor is involved ext .
..& d A al . . . ens1ve1y .

l\Ce~·
~,~&

tests are pe, ,orme . pprov m operation 1s needed by th , site a
ealth d ati e project cceplati environmental, h , an s ety personnel, before &cceptan teain, in

1
_ce

validate that the equipment performs as intended, that the ce. :he Pllrpo~eu~,ng
is achieved, and that environmental, health, and safety spec ·fi. qu~.hty leveJ ex~ to

I Cations have bee lC(J
In Production

nlllet

At this stage, Kaizen–continual improvement-is a goverru
quali · · · d Adh ng concept s ty IS mamtame . erence to standard operating proced . · Upetior

. . th ,u . ures, Includ’ pracbces, IS e norm. naste Is constantly sought after and redu d ing safe ce .

5S Review

Since this organization has made applying the 5S system a core value a final • .
• rev1ew1s made to assure that all 5S system elements have been maintained: Sorting, Simplifyin

Systematic Cleaning, Standardization, and Sustaining. g,

The 5S Concept

Originators of this Lean/Design process were asked to critique this chapter for
technical accuracy. This is one of the comments made: “We have found that 5S is one
of the foundations of lean. As far as safety is concerned, nothing makes hazardous
conditions and practices stick out more than a well-organized facility. ~ou should
expand on 5S and how it can help improve safety performance.” . his

His premise required further inquiry into how the 5S program o~rates.:ng a
facility. They say that their 5S program is an underlying reason for th:i::ie~ualllY·
bundle of awards on employee safety, environmental management, and P lid impact
Personnel who critiqued this chapter say that the 5S concept c~•bave ~s~utstanding
on worker safety and that i( is folly, to expect good work pracuces an d disorderly,
performance from workers -if the work environment is dismal, messy, an
and operational discipline is lacking. Comment on the 5S system f~llo:~t needed, ~I

Sorting, the .first step in a 5S application, is to get rid of everythithng t orderliness ist
th d li When a · rnen e cluttering, and to achieve an atmosphere of .or er ness. and eqUIP d
achieved in operational and storage areas-both for work in proces:d hazards an

. e iffiprov , needed to do the work-efficiency and housekeeping ar . rminated-
risks are reduced, and time wasted searching for work items is e 1

THE COMPANY’S LEAN-DESIGN PROCESS 353

. . the next step in the 5S process. If there is a place for everything
l :klflg is 11 k d SifTIP !J: th se places are we mar e and labeled and known to the staff it is and o . ‘

tained, d t ols, parts, and the equtpment needed to do a job and to keep things
reasier to~ ;fying in a disciplined ~anner promotes identification of hazardous
e roerlY• SinidP makes it easier to get things done with less risk.
0

· ns an · th hird · 5S E · illlau0 • cleaning is e t step m • veryone 1s to be involved in the 5
syste~:aning endeavor. Workers in a ~nit are assigned ownership of and respon-

systemauc the cleaning tasks. The purpose 1s to produce orderliness: Dirt, disorder, or
·i·”‘ for · · th · sibl “1 red in aisles and getting m e way or stored m a manner that makes their

(hing5
st0

hazardous are not tolerated. The cleaning processes are to add to operational
recovery t eliminate waste, and to reduce risk.
tliciency, o h . 5S . e nd rdization, the fourt step m , 1s to adopt the best practices for equip-

5,a : machinery layout, and the design of equipment and work practices for
men~:vity, mis~e-pr~ofing_, and continual i~pr?vement. Workers at all levels
prod opportunities for mput mto the standardization procedure. Comments are
:::;ht on th~ design of the work methods, for efficien,cy as well as to avoid risky
situations. . . .

s·nce at this location, accidents are recogmzed as a. form of waste, safety is an
inte~al part of tb,e standardization process. Performru;ice standards and expecta-
tions for predictable results are set. Oper~tiona\ breakdowns are to be few and far
between. Causal factors for operating problems are studied and largely eliminated
on an anticipatory basis. Up-front prevention is the thinking. Methods to identify
possible breakdowns and how to respond with as little waste as practicable when
they occur are a part of the standardization procedure.

For maintenance personnel; that makes :their work easier: Thus, they are exposed
to fewer hazardous situations; jerry-rigging for unusual work is not condoned. It is
emphasized that maintaining tight control over ,the ‘management of change procedures
is an integral patt •of.the· standardization element•in 5S.

Sustaining what has been accomplished in the four previous steps is the fifth
step in the 5S concept. This, they say, is the most difficult step after superiority
is attained in the first four steps. It is expecte& that sorrie workers might revert to
previous practices, particularly with respect to cluttering the workplace and
avoiding cleanliness : Sustaining the concept clin be achieved only by continuous
managemenHeaderslii p. ‘ ·

The CEO·in this company says that he knows he must, continudusly and person-
~lly, embrace the 5S concept and both talk the talk and walk the talk, repeatedly’. He
: visible and involved as ‘he holds his staff accountable for sustainin’g what they
:ve achieved-an orderly and· stable work environment in which efficiency is at a

gh level, -:vaste is ‘as low as reasonably·practicable, and hazards and risks are at an
acceptable level. , . ‘ .

rea~om~ organizations have added a: sixth’ S to their system to stress safety. But ih
inte;· _if~ ~S system is installed and m.ahaged properly, safety is integrated -and
to th:~n:~tt~ all of the first ?Ve ~t’e~s-:: It c~n be argued tha~ adding a separate S
rnana Y m for safety creates the ‘1mpress1oh that safety 1s separate from the gement sy t

s em and could produce adverse consequences.

S-EMPHASIZING THE DESIGN PROCESS: SECTION S
1 3

354 LEAN CONCEPT . . OF= l10

REAL-WORLD OBSERVATIONS

l attempts by organizations to improve operations by a . Unfortunate y, some ‘d . u, t . . PPly
10

t . eluded safety cons1 erations. norse ye , existing syste~ g leAh concepts have no m Ii ti’ th .,,s to c … ,
. bee erridden in some lean app ca ons, e result beino that h on1txi

1
nsks have n O¥ . R fi · c, azar
. . that ere addressed preVIously reappear. etro tting for correcti do

118
s1tuat1ons w . ful d •

0
n of th be difficult but is certainly waste an expens.we. . oSe hazards may . th ti hi h v- · -,.r , h b rved situations similar to ose or w c n.ev1n J.-,ewman anct ‘h.. I ave o se . . . , ‘1tod B

ffer caution in “Advice on mcorporating ergononuc safety initiati· _ore
raun o ., Th . Ves int your continuous improvement process. ? say. _ o
Unfortunately, “Lean’• doesn’t n

1 go hand in hand. After ail, a_ poorly . design’:’. task that ‘.”

In the worst-case SC

Newman and Braun imply that ergonomics risks occur if the WOQc ~Qire, “•~
to reach excessively” and if there is ”!Iie• ril!k ,of overexertion:• If ,ergonomics-related
injuries occur, one of the central themes in lean-avoiding interrup.tiol}s in the work
flOW—is negated. While all hazards,1111d risks shciuld be ad\lressed in a lean~
applying ergonomics principles fits pm;tictJ]arly well within a lean initiative .

• I ‘

A MAJOR WORK oN sAfefy ANo LEAN
Otbei: safety professionals ha~e recogniz.ed the of i.nfurmation in the lean lirera·
lure about how safety and lean can be integrated, They have also encQuntered situations
\\dJere safety concepts illld lean applications were in c;onflict, .with the results being far fu/m satisfuctoiy, • . .

. . . :, ,. ‘ 11
TheAssocllllion For Manufacturing Technology (AMT) has publishedANSIB_ ·

TR
7 2

007, Designing fot Safety and Lean Manufacturing: A guide on integra/lnB
safety and lean manufacturing principles in th~ use of machinery. .

Al!hough the PlI1’J)ose is to address 1e,ii; and ~af ety concepts in the use of machi~’;;
~is lecbnical repo~ can be valuable to all safety professionals who becom~ invo ve
in lean. Its content IS largely generic and the principles apply to all enterpnses.. ed

TR
7

provides gtJidance on how a low w- le~el at a low-risk level can~ ac~~
and helps fill

th
e gap in the technical liter;,ture on lean and safety. This

18
ho abstract reads.

CONCLUSION 355

. g includes a variety of initiatives, technologies-and methods
facturtn d f Jllaflu roductivity (better an aster throughput) by reducing waste ‘ ,,.an rove p . ‘

v~ 10 illlP lexity from manuf~<*m~g p~ocesses. However, the effort to get 115

15 and coIJlP ently led to the nusapplication oflean manufacturing principles
cos bas 100,freCJUlt in significant risks to worker safety and to the goal of lean
Jellll tbat resu
. ways .
111 .. ,ring. · th 1 f t · ” · .nufacw» ·u·cal element m e ean manu ac unng euort to yield processes
Jll”” ·s acrt .

safetY 1 ‘-“aster, less wasteful and safer. This document provides guidance 1,etter, 1, • • _c • 1 (bat are ponsible for mtegratmg swety mto ean manufacturing efforts.
rsons res ‘bl ‘f 1 c · for pe . n is only poss1 e 1 ean manu1actunng concepts and safety

‘}’his integrfau:chinery are addressed concurrently.
rns o 01 c • • conce . f erview oflean manu1actunng concepts 1s presented. The challenge A bri:.;:tly addressing safety and lean is described and examples demon-

of con~ tions where this has not occurred.
strate s:=ss model· for safe and lean is presented. · A risk assessment framework
. ~tfuied that demonstrates how lean manufacturing concepts and safety can be
‘.
50

1 ented concurrently. Examples where safety and lean have been successfully unPli: are shared, This documen_t ~so provides design guidelines on how to meet
app b,iectives without comprormsmg safety.
lean o . . · . –

Safety professionals were prominent in the dev:elopment of this technical report.
It is a good resource for concurrently adcµ:essing safety and. lean.

CONCLUSION

Because of the base on which the lean concept is built-removing waste from
a system-lean will probably have staying power. Since accidents and their conse-
quences are so fundamentally wasteful, preventing them should be an integral part of
lean applications. From the very beginning, when an organization begins to discuss
adopting lean concepts, safety professionals should step forward to become members
of the lean team.

There is opportunity here to address hazards and the risks that derive from them
as Processes are designed and redesigned. To be meaningful participants, safety
professionals must become familiar with lean concepts. Several helpful resources
on ~an are listed following the References for this chapter.
avai/~0 • an Internet search indicates that several courses on the lean concept are
oped a le. For example, the Society of Manufacturing Engineers (SME) has devel-

Eac~urses that award lean certificates on three levels.
eitherc progressive level of lean certification requires continuing education-

academic c · · c · b t the SM£ oursework or structural classroom trammg. ln1ormat1on a ou
http://ww courses and its Lean Certification Body of Knowledge may be found at
learning.”W.sme.org/. As the SME literature says, “Lean thinking requires Lean

••
356 LEAN CONCEPTS-EMPHASIZING THE DESIGN PROCESS: SEC TION 51

REFERENCES
. . aoi:-.

<-1Q

ANSI/AIHA ZI0-2012, American National Standard, Occupatio l
Management Systems. Fairfax, VA: American Industrial Hygiene Ana Health a

. . h •/’, ssociati 11d S is now the secretanat. Available at ttps. ,www.asse.org/cartpage h on, 20 12

Sa·”‘ety and lean manufacturing principles in the use of machinery Se guide on int ‘ !f’ • cretai; egra ,
Standards Developer, B11 Stand~ds, Inc., POB_ 690905, Houston, T atandA.cc~’ng
American National Standards Institute-www.ans1.org. X 77269, Alsole,;t

EPA Lean and Environment Toolkit. “How to Incorporate Environmental C . at
Value Stream Mapping.” http://www.epa.gov/epainnov/lean/toolkiVch

3
honstderatio081 . tlll#defi . nto

Hafey, Robert B. Lean Safety: Transforming Your Culture with uan Mana 111tion,
. gemem 11., Production Press, 2010. · . · ,,ewy0rk:

Newman, Kevin and Theodore Braun. “Advice on Incorporating Ergonomic Safi ..
into Your Continuous Improvement Proc~ss.” Occupational Hazards Au

2
ety Initiatives

. ‘ g, , 20()5
Womack, James P., and Darnel T. Jones. 1!,ean Thinking: Banish Waste and c ·

Your Corporations, 2nd ed. Northampton, MA: Free Press, 2003. reate Wealth in

ADDITIONAL READING

Dennis, Pascal. Lean Production Simplified: A Plain-Language· ‘Guide to the World’s Most
Powerful Production System. Shelton, CT: Productivity Press, 2002.

Hallowell, Matthew R., Anthony Veltri, and Stephen Johnson. “Safety & Lean.” Professional
Safety, Nov. 2009, pp. 22-27.

Imai, Masaaki. Gemba Kaizen: A Commonsense Low-Cost Approach to Management. New
York: McGraw-Hill, 1997.

Main, Bruce, Michael-Taubitz, and Willard Wood. “You Cannot Get Lean Without Safety,”
Professional Safety, Jan. 2008, pp. 38-42.

1
• , ,

Rother, Mike and John Shook. Leaming to See: Value _ Stream Mapping to Create Value and
Eli/ninate Mut/a. Cambridge, MA: Lean Enterprise Institu,te,, 2003.

Taubitz, Mi.chael. “Lean, Green & Safe.” Projessional-Safety, May 2,010, PP· 39-46·

AooENDUMA

A SIMPLIFIED INITIAL VALUE STREAM
MAP USED TO IDENTIFY WASTE
(MUDA) AND OPPORTUNITIES .
FOR CONTINUOUS IMPROVEMENT
(KAIZEN)

B C D E F

Defects: The machinery at station A is old and worn. Regardless of the amount of
tinkering, it cannot achieve a quality defect level lower that 3 parts per 10,000.
Producing defects at that level, below some customer specifications, is wasteful.

Motion: Adjustments of the machinery at Station A and die changes must be
made frequently. That is wasteful motion and adds risk. Also, the lockout/
tagout device is over 100 feet from the machine. An arrangement of that sort is
error-provocative and promotes risk taking. Getting to and from the device
wastes time.

Because of customer specifications, all parts processed at Station A are inspected
at station B. Parts are moved to Station B in carts. Since the casters on the carts are
too small, moving them is cumbersome and time consuming, and they are tippy.
They have tipped over, injuring workers and damaging parts. This inspection
motion is expensive, wasteful, boring, and adds elements of risk.

Overproduction: At Station C the machinery processes parts faster than can be
handled by the remainder of the production line. Thus, materials in progress
get stacked in aisles until they are transferred to a storage area. Having excess
materials in process is wasteful. An additional result is overly stressful manual
material handling and the ergonomic risks that implies.

Transportation: Station D represents the wastes deriving from the additional
storage space and material handling needed because of overproduction at

1dvwrced Safety Management: Focusing on ZJO and Serious Injury Prevention,
©~ 0nd Edition .. Fred A. Manuele.

Ol 4 John Wt!ey & Sons, Inc. Published 2014 by John Wiley & Sons, Inc.

357

358 A SIMPLIFIED INITIAL VALUE STREAM MAP USED TO IDENTIFY WASTE (MUDA)

Station c. The storage configuration is not conducive to efficiency. Aisles are
!)arrow. Powered vehicles hav.e, collided, have struck workers, and gOOds have
been damaged.

Waiting: Although overproduction occurs at Station C, personnel at Station E
often are not fully occupied, and waste occurs while they are waiting for other
components to be delivered. Inventory controls are inadequate, and the motor-
ized delivery system is inefficient and risky.

Inventory: The inventory at Station D is greater than needed, and thereby wasteful
Excessive materialJandling is ne~essary. ·

Overprocessing: Because the quality leve_l achieved at Station A is inadequate for
some customers, considerable parts rework is necessary at Station F. That wastes
resources, and use o( the machinery in the process adds risk. .

Unit Assessment

QUESTION 1

A manufacturing facility that makes steel materials handling devices such as hand carts and an assortment of roller carts for moving heavy materials around in manufacturing facilities has decided to start making cantilever storage racking systems. This will require the purchase and installation of a 12-foot hydraulic press brake and a 12-foot shear in the fabrication department along with the necessary tools and dies to bend and punch holes in the rack components that will largely be manufactured from formed sheet metal. Employees have experience working smaller versions of this type of equipment, but room will need to be made and larger pieces of sheet metal will need to be cut and handled. The department will also need to continue to produce existing orders while the new equipment is installed. How can a management of change program be used to reduce risks in such a scenario?
Your response must be at least 75 words in length.

QUESTION 2
Your organization, a company that manufactures fitness equipment such as treadmills and elliptical machines, is about to introduce lean concepts into its operations in order to be more competitive with foreign manufacturers. The foreman from the assembly department, however, does not think that his employees have the time to be involved with the lean initiative. Provide a convincing argument about why it is important for the assembly line workers to play a part.
Your response must be at least 75 words in length.
QUESTION 3
Your purchasing department does not want to buy adjustable hydraulic pallet stands for the filter assembly line at a company that makes oil filters for cars and trucks. They state that the current process works just fine and that expensive, adjustable stands are not required in the Occupational Health and Safety Administration standards. The production employees in the facility are largely female and many have worked at the facility for decades. The current process for accessing filter parts entails having assemblers bend over to pick up arm loads of the various filter components from a pallet or bin and placing them on a table beside their respective workstations. The parts are assembled and pressed into place, and the completed product placed in a separate bin. Please provide a risk-based argument as to why the adjustable pallet stands would be the better choice.
Your response must be at least 200 words in length.