Changes to safety-critical positions in regulated industries must follow a process to manage risks associated with transitioning a new person into a role or when the position itself has changed.
The need to manage organizational change safely is called out by various regulations and standards such as:
OSHA 1910.119
40 CFR Part 68
PHMSA RP1173 Pipeline Safety Management
National Energy Board (NEB)
CSA Z767-17 Process Safety Management
And others
This process is one of several to manage change safely and is often part of an overall Management of Change (MOC) program, and is commonly referred to as:
Organizational Management of Change (OMOC) or
Management of Organizational Change (MOOC)
At a high level an OMOC process will follow steps similar to the following diagram:
The first step is to scope out the change to collect relevant information and identify possible risks and impacts. This information will be used to determine appropriate actions to successfully transition the role or position.
The OMOC Facilitator is the role assigned to the person who is responsible for the personnel change and who will conduct the scoping activity usually in an interview format. The best time to conduct the scoping interview is when the incumbent (i.e. outgoing person) is still in the existing role. This will help to identify if critical knowledge needs to be captured along with undocumented duties or activities that need to be transitioned.
In many cases it is only after the role has been vacated that the change is initiated and the scoping activity can be done. For vacated positions a temporary change maybe necessary to cover safety-critical roles until the position is permanently filled.
The following template has been used to scope hundreds of personnel changes affecting safety-critical roles.
OMOC - Scoping Interview Template
Interview Facilitator:
OMOC Facilitator (or Implementer)
Who should attend:
Roles that are typically involved in the scoping interview include:
Outgoing Person (incumbent)
Incoming Person
HR Representative
Immediate Manager
OMOC Facilitator Instructions:
At the onset of the interview it is helpful to remind everyone that this is not a performance review of any kind. The purpose of the meeting is to identify any gaps in accountability, authorities, and duties, along with other impacts that may arise from the transition to or changes in the position itself.
With the help of those participating in the interview, the OMOC Facilitator will identify relevant information to understand what is being changed and what steps have already and that still should be done to fully implement the personnel change.
It is important to identify and document all changes to:
Regulatory roles such as: Steam Chief, Incident Commander, On Call, Compliance Officer and so on, along with
Compliance management roles, committee and project team assignments
All transition steps identified in this meeting should be tracked so that progress along with risk mitigations can be monitored. Review this list with all participants prior to the conclusion of the meeting.
New positions can be difficult to address as they may not yet have adequate accountability documentation prior to the change being initiated. You may need to use the job description along with information from a corresponding org structural analysis (if this is part of a structural change) where changes in accountability and authorities have been defined.
Temporary assignments will require additional care and should be captured and transitioned appropriately. Make sure that dates are recorded for when the temporary assignment should end and add a step to verify that the permanent transition has occurred.
Background Information:
Document any background information that will help identify transition steps and possible risks:
How long has the person been in the role?
List certifications and qualifications the incumbent has (some may not be required formally in the role but may have been relied upon as backup coverage for other roles)
What other circumstances may impact the successful implementation of this change?
Scoping Questions:
These questions serve as triggers that will be aid in the development of appropriate transition, communication and risk mitigation plans.
1. What is being changed as part of this personnel change:
Transferring into a new role
Transferring into an existing role
Transferring out of an existing role
Staying in the same role but with changed accountability, authorities, or assignments
2. What is the reason for this change:
Structural change (previous position no longer exists or has been redefined)
Job transfer (permanent, temporary/acting)
Leaving the organization
Joined the organization
3. Does the change involve a position with potentially significant PSM impacts such as changes to:
Emergency Response Personnel
Health and Safety Personnel
Environmental Personnel
Process Operator (or technician)
Line supervision or management
Maintenance Personnel
Technical operations support (operations engineer, plant engineer)
4. What steps are needed to transition previous accountability and authorities?
Reassignment of existing tasks
Reassignment of compliance program assignments
Contacting chairs of committees, working groups, or project teams
Documenting critical knowledge
Training new person in previous position
Covering previous accountability and authorities until another person fills the position
Updating of any training, procedures or work instructions
Notifying any regulatory authorities
Updating any systems, databases, or records
Other steps
5. What steps are needed to transition into the new accountability and authorities?
Management on-boarding
PSM on-boarding
Job orientation
Specific training
Operator qualification
Other steps
6. What risks are anticipated during the transition or after the change has been implemented:
Critical work will not get done in a timely manner
Critical skills or certifications will be lost or reduced
Increase in workload due to covering previous duties and responsibilities
Preparation of regulatory reports will be impacted
There are potential impacts to the health and safety of people, process, or the environment because of this change
Other risks
7. What steps should be taken to mitigate these risks?
Discuss risks with new or previous manager
Communicate risks to affected compliance program owners (PSM, HSE, Quality, etc.)
Other actions
8. What is the target date for when this change will be implemented (i.e. all transition steps completed)?
9. Identify and list all: transition steps, communications, and risks
Review list with participants
Enter this information into the OMOC tracking system and operational risk registers
To learn more on how to manage organizational changes safely and meet regulatory standards and guidelines visit our web site at (www.leancompliance.ca).
