Management of Change & PTD

Hand-in-hand with the growing focus on risk is a renewed interest in prevention through design (PTD) concepts and methods, which involve assessing hazards and potential risks early on in the design of systems, products and facilities. According to Frank Renshaw, Ph.D., CSP, CIH, with Bayberry EHS Consulting LLC, management of change (MOC) needs to be a focal point for PTD integration. “The MOC process is defined as a system to assess and address the EHS impact of changes to a process, facilities or organization before the changes are made,” Renshaw says in his Safety 2013 proceedings paper.

Adherence to four principles is key to MOC success, Renshaw explains:

1. Every change must be managed. 
2. Changes must not be made without an appropriate review. 
3. The type of review should be consistent with the complexity of the change. 
4. MOC systems should be simple to use. 

“This first principle underscores the fact that MOC is by no means meant to be restricted for use with major projects.” Renshaw explains. “It is intended to be used for projects of all sizes.”

The second principle, review before making changes, aligns well with PTD, Renshaw writes, because PTD calls for the elimination of hazards and control of residual risks at the source or as early as possible in the life cycle of a project. “This is best accomplished through the review process, drawing on appropriate hazard analysis and risk assessment methods.”

The third MOC principle “addresses the practicality of reviewing the volume of changes to be encountered by matching the complexity and resource requirements of the review process to the level of change under review.”