Change Analysis

What is it, and Why is it an Advantage?

As manufacturing facilities grow, add processes, and introduce new equipment, is employee protection considered in the process or are potential concerns identified after the building modification, line changes, or new or relocated equipment are introduced? If you have ever experienced the latter, you know how frustrating it is to make modifications for safety after the fact. 

A Change Analysis is a means of managing alterations to the working environment that affect employee safety and health. The goal is to reduce or eliminate potential hazards that may result from the process before production begins. This is an ongoing process that does not cease once the building modifications have been made, the machine has been moved, or new equipment enters the production process. Continued evaluation will often identify items that were not considered during the other phases of the assessment.

For facilities subject to the Process Safety Management (PSM) standard, management of change is a required part of the process for new and modified facilities when the modification is significant enough to require a change in the process safety information.

Where to Start

First, assemble a team of people to help conduct the evaluations. This should consist of EHS personnel, engineers, project management, maintenance personnel, and safety committee or Union members. This ensures that there is a diverse knowledge base to draw from and allows for a more thorough assessment to be performed.

If a new machine is being purchased that is substantially similar to existing equipment in the facility, evaluate the existing equipment to develop a list of safety concerns that can be addressed through engineering methods for the new equipment.  If designing the machine from the ground up, take the opportunity to review the engineering drawings to identify areas that require further modification.

If an existing machine or production line is being relocated, evaluate the equipment in its current location and review the new location. This will identify existing opportunities that can be corrected during the relocation and will alert the team to any potential hazards that might arise once the equipment has been moved. This can include space limitations, material staging considerations, and potential exposure to high traffic areas in addition to guarding needs, lighting needs, and lockout procedure modifications. 

Factory Acceptance Testing and New Construction

If the equipment is new to the facility and has been custom designed, have members of the Change Analysis team attend the factory acceptance test. This will allow them to evaluate additional guarding opportunities, identify if energy sources are in a hazard area (e.g., inside a guarded space), and any other areas that require modification before the machine is delivered to the site. 

If the equipment is being placed inside a building expansion, evaluate the proposed placement of the machine(s) to determine if there are any potential concerns for emergency evacuation, fire suppression needs, placement areas for eyewash stations, potential for obstructed sightlines, etc. Give yourself the necessary time to get corrective actions in place before production lines are installed.

Equipment in Place

Once existing equipment has been moved or new equipment has been delivered, evaluate the line for additional guarding opportunities, make sure machine specific lockout procedures have been written or revised, machine sounds (such as alert tones) do not make surrounding emergency alarms or forklift back up alarms inaudible, process piping has been labeled, and note any outstanding items that could not be identified without the equipment in place.

If additional guarding opportunities or other interaction issues are discovered that will take time to address, develop standard operating procedures to train associates in appropriate machine interaction that can be monitored and enforced by supervision and management. 

Post-Commissioning

Once the equipment is installed and operational, perform another evaluation with the assistance of operators to identify any additional hazards, training opportunities, determine frequency of upset conditions and potential contributing factors, set-up and changeover tasks, and the preventive maintenance schedule.  This post-commissioning analysis may need to be repeated several times until all the identified items have been addressed.

By managing change in the workplace effectively, the potential for downtime, operational difficulties, accidents, and injuries can be substantially decreased. 

Tags: Change Analysis, Safety, Working Environment