All changes to an organizational structure or changes in personnel with specific Knowledge, Skills, Experience, and Behaviors (KSEB) must be assessed to understand the impact of the organizational change on safety. Any organizational change has the potential to introduce safety hazards and risks, and therefore, all changes to an organizational structure or changes in personnel with specific KSEB must be assessed to understand the impact of the organizational change on safety.
Where proportional to do so, the change owner must decide whether an Organisational Safety Assessment (OSA) needs to be conducted.
Organizational change encompasses any changes affecting the structure or range of duties currently conducted by personnel within that organization and may include:
- mergers,
- organizational restructuring,
- transfers of personnel,
- changes to staffing levels, and
- alterations to procedures, roles, and responsibilities.
An Organisational Safety Assessment (OSA) is a formal and systematic process that is used to assess the proposed Organization and Arrangements (O&A) compared with those in place before the organizational change and identify any potential safety risks and the required mitigation measures to manage those risks to ALARP and tolerable. The OSA is a logical, phased evaluation of the impact of the organizational change on safety from the conception through to the implementation of the change and is used to ensure that there is no adverse impact on the safe conduct of activities resulting directly or indirectly from the change.
When organizational change occurs the change owner must decide whether an OSA needs to be conducted. It is for the change owner to determine the appropriate authority
and relevant competency required. If additional guidance is required, then the change owner should consult with their Process Safety Leader/SME or equivalent or the nominated OSA point of contact. The change owner must make an initial assessment of the change and decide if an OSA is required; if so, then the scale of the OSA should be proportionate to the complexity and scale of the proposed change and must be conducted by a person in a position of authority, with suitable KSEB to conduct such an assessment.
Organizational Safety Assessments – Process guidance
- The following Organisational Safety Assessment (OSA) process guidance aims to:
- Describe the requirements, roles, and responsibilities for assessing organizational change impact on safety risks managed within an organization;
- To provide guidance on responsibilities for safety during any transformation, and
- To define the content and process for conducting and assuring an OSA.
Background
Change is an inevitable part of business improvement at all levels in an organization, from increasing the efficiency of a process or updating equipment to making major changes to organizational staffing and structure. However, while the impacts of simple changes can be readily assessed to demonstrate their effectiveness, those at the organizational level can be more difficult because of the complexity involved or the lack of recognition of the potential impact on standards of safety.
The evidence for this comes from investigations into significant safety accidents worldwide. The Haddon-Cave Review, following the loss of Nimrod (XV230), observed that
“MOD suffered a period of deep organizational trauma between 1998 and 2006 due to the imposition of unending cuts and change which led to the dilution of its safety and airworthiness regime and culture…”.
Application
This OSA guidance applies to all levels of organizational change, from the strategic to the tactical. However, it is recognized and accepted that the OSA should be scaled as required and proportionate to the proposed change.
The management of organizational change naturally focuses on risks that impact the desired outcomes. However, this focus can be blind to unintended consequences such as
degradation in the arrangements for managing safety.
When considering the need to implement organizational change, change owners must:
- appoint a Senior Responsible Owner (SRO) (at the concept of the change) with the relevant competency and responsibility to undertake an OSA;
- make sure that the SRO undertakes an OSA to assess the impact on the safety risks being managed by an organization;
- make sure that the SRO undertakes an OSA that is proportionate to the complexity and scale of the proposed change and
- ensure that the senior leader in the organisation or delegated individuals acknowledge any detrimental impact of the change and put in place effective preventative and protective measures to mitigate the risks identified by the OSAs, within their Areas of Responsibility (AoR), to ALARP and tolerable.
The SRO is responsible for defining the scope and complexity of the OSA, and how rigorous it needs to be depending on the potential to degrade safety standards, seeking
advice from the Safety Leader/SME or equivalent when required. The SRO should consult with the appropriate Safety Leader/SME or equivalent on the scope and assurance requirements of Dwide or cross-organisation OSAs. The Safety Centres / CESOs or another department as detailed within the Defence organisation’s procedures should maintain appropriate records of OSA’s for their organisation.
At the initiation of any change initiative which results in organizational change, the change owner and SRO should define how extensive the OSA should be, informed by the
potential for the organizational change to impact on safety standards. This is a fundamental and critical decision because it will determine the subsequent nature of the OSA. The change owner should be identified in the program governance arrangements, and the SRO should be identified as the person responsible for implementing the change program.
The change owner and SRO should be able to demonstrate that the OSA is an integral part of any change management program and:
- has been initiated at the concept stage for any proposed change initiative;
- is proportionate to the complexity and scale of the change proposal;
- remains a live document throughout the change process until it has become business as usual;
- has nominated owners and appropriate governance;
- is considered as necessary, as part of any wider change program and its planning process; and
- required actions are costed and resourced and are included in the evidence submitted at the programme’s approval board as part of the investment approval
business case.
The SRO should formally advise the senior management or equivalent of the intention to undertake an OSA and should be able to demonstrate consultation with the
Safety Leader/SME or equivalent and affected departments/units when managing change. The SRO should be able to demonstrate that the OSA is comprised of six phases (see Annex A) that reflect the stages of an organizational change program and a written record of decisions, assessments, and actions at each stage.
Typically, the following types of organizational change represent those that have significant potential to impact on the standards of safety:
- Changes to Duty-holding arrangements may have a high potential impact on the management of Risk to Life activities. The significance of such changes is such that the relevant Defence Regulator(s) will need to be assured by the OSA that the impacts of any changes are being fully mitigated.
- Major re-organization of staff or re-alignment of senior management responsibilities. The decision on whether this will influence safety standards will be dependent on the size of the organization and the levels at which management responsibilities are held.
- The transfer of infrastructure and sites from or to another organization will result in changes to the management arrangements that may have safety impacts;
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