Organisational change - HSE inspector's toolkit

SPECIFIC TOPICS Specific topic 3: Organisational change and transition management Introduction Fig 9: Managing organisational change

This can range from simple limited change (e.g. Step 1 Getting organised apparently minor change in supervision Have a strong policy arrangements for shifts) through delayering, takeover / merger changes, multi-skilling etc to a Make senior-level managers accountable Have a clear change-management procedure full business process re-engineering (BPR) Communicate and include everyone exercise. Review and challenge

The key issue is the identification and assessment of effects (direct and indirect) on the control of MAHs on site from a proposed change, Step 2 Risk assessment and during the transition to the new structure. In Identify the people involved the case of the apparently minor supervisory Identify all changes Assess the risks change at a TT site, there was a real – but Consider human factors, competence and unassessed – impact on this control, and the workload Test scenarios team provided substantial support for the inspector concerned in dealing with this.

The Human Factors Team have developed and Step 3 Implementing and monitoring published an information sheet on the Provide enough resources to make the change management of organisation change safely Monitor risks during change Keep your plan under review, track actions Guidance is available (Contract Research Report Monitor performance after change 348/2001, commonly referred to as the ‘Entec Review your change policy report’) on determining staffing levels. This does not, however, provide all the answers. It can be used to confirm (or not) that the levels of staffing in place/proposed are adequate, but if the level is not adequate the guidance will not tell you by how much it needs to be increased (i.e. needs to be used iteratively to determine an adequate level). This Entec guidance does not work well for highly automated plant.

Specific documents

In addition to the general documents that should be requested prior to the visit (seechapter ‘Aim of the Guidance’) it is recommended that the following documents, which are specific to this topic, should also be requested:

1. Management of (organisational) change policy and/or procedure;

2. Risk assessments from previous or current change process.

Enforcement and advice

Improvement and Prohibition Notices have been issued on transition risk assessment and training for major BPR exercise at a large TT chemical site. Extensive advice and support for major organisational change at an oil terminal following new ownership. The Human Factors Team also recently provided support for an extensive investigation of organisational change offshore.

This is an area for which the Human Factors Team have developed much expertise.

Guidance

3. Business re-engineering and health and safety management: best practice model Contract Research Report 123/1996.

4. Organisational change and major hazards; Chemical Information Sheet No CHIS7 (see below)

5. Assessing the safety of staffing arrangements for process operations in the chemical and allied industries; HSE Contract Research Report 348/2001.

6. Development of a multiskilling life cycle model HSE Contract Research Report 328/2001.

Question set: Organisational change and transition management Question Site response Inspectors view Improvements needed 1 Is there a robust procedure for management of organisational change with: 7. Clear objectives? 8. Clear leadership from senior management? 9. Structured, to a prescribed, consistent process, thorough, well documented? 2 Is there an assessment process that: • Identifies and maps all changes to both tasks and personnel that could have an impact on MH prevention, no matter how small the change? • Is facilitated by well-trained persons independent of the facility being assessed? 3 Does the risk assessment methodology guide assessors to take full, realistic account of the range of human reliability? This may include: • Workload (including non-productive work); • Competence; • Work priorities; • Team work and communication. 4 Where applicable, are there realistic assessments of the organisation’s handling of a range of crisis scenarios post-change, including upsets, escalating incidents and emergencies? 5 Are all assessments fully participative, ensuring that the knowledge (including informally held knowledge) and views of people involved is gathered and given dispassionate consideration? 6 If outsourcing is considered: • Is major accident prevention accepted as core business? • Are there arrangements to continue, and resource, effective control of outsourced major accident risks? • Have appropriate performance indicators been selected for signs of degradation of performance? 7 Where required, is there a competence assurance process to ensure adequate transition arrangements? • Does it include identification of training needs for changed or additional roles in relation to major hazards/process safety – bearing in mind that some key knowledge may well not be documented? • Is there adequate planning for competent cover during the training period? 8 Is there an overall view of site or business-wide requirements for the core technical competencies required to keep risks ‘ALARP’, including capacity for engineering and adequate, intelligent supervision of contractors?

Question Site response Inspectors view Improvements needed 9 Is there a mechanism for reviewing decisions, and to ensure that all necessary measures are in place before ‘go-live’? 10 Are there plans to monitor performance indicators well beyond the end of the transition?