Regardless of the maturity of a facility, changes will occur that may impact the environment or require additional permitting with regulatory agencies. Identifying and understanding the impacts of the changes is an essential element to an effective Environmental Management System (EMS). The following are some tips to successfully manage change.
- Define and communicate what constitutes a change. Consider that a change may be a physical change to equipment or processes or it may be something more subtle like a change in responsibilities, positions, or organizational structure. You may also choose to exclude specific activities that are either routine or are simple in-kind replacements of equipment or machinery.
- Establish a formal system to review changes. Make the system comprehensive enough to minimize the risk of non-compliance, yet making it simple enough that employees will be encouraged to use it. The system should include:
- Stakeholders who are directly or indirectly impacted by the change.
- A review of regulatory requirements and permitting required prior to implementation.
- A formal approval process that authorizes the implementation of the change.
- Documentation and justification for the proposed change, along with the projected benefits.
- A formal risk assessment process to assess the likelihood and consequences of impacts from the proposed change.
- Actions that must be implemented prior to execution of the change.
- A review of the implemented change after execution to assess the effectiveness of the controls and evaluate the benefits realized.
- Documentation or actions that will be required post implementation (i.e. as-builts or record of construction reports).
- Define who is required to follow the change management procedure. In addition to employees, this may include contractors, vendors, and consultants who may work at your facility.
- Establish a documentation procedure for the change management system such that completed changes are archived. Previous documentation should be catalogued and searchable such that employees can access them for future change reference.
- The management of change, which may impact the environment, may be incorporated into a more global change system that also assess for impacts to safety and health, production, community, or other areas of concern.
A change management system is an essential element of a successful EMS. Managing change is necessary to protect the environment and ensure regulatory compliance. What systems do you use to manage change?