Much like it is in process safety, the Management of Change (MOC) tool may be the most despised element of an SMS. However, a recent safety assessment with a local client identified the lack of performing an MOC on significant changes to production machinery and rates. The facility is NOT a PSM facility, but they are ISO45001 “certified.”
Last year, the facility had four (4) recordable hearing loss cases (e.g., a loss of 25 dBs), which got corporate asking questions. I was contacted to see if I could investigate and determine the causes that led to these recordable illnesses. Of course, I started with the written HCP and all the required actions the plan calls for. I immediately noticed that the facility’s HCP stated an attenuation evaluation would be done for each type of HP provided; the facility had not conducted this evaluation. As it turns out, the HP being provided could only attenuate exposures to less than 90 dBA, not the required 85 dBA for those who had suffered an STS. And almost 50% of the employees in the HCP had suffered an STS over the previous three (3) years -YES, that is very high percentage!
I then went to the exposure data, where the wheels came off!
The facility had undergone many “improvements” and growth over the previous four (4) years. The business consolidated three facilities into one and moved into a new building. However, the business has not updated its Noise Survey and Personal Sampling with the new building and equipment layouts. Add this to the fact that the HP being provided was inadequate! The business immediately hired an IH firm to come in and perform some noise sampling to establish exposures. Management was not happy and began to point fingers at the OSH manager. But this professional had plenty of evidence that he/she had made it clear that a new building, new machines, new layout of the machines, etc. would need an MOC to manage this change. Remember, this is an ISO45001 certified facility.
