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agreement of criteria and mechanisms for handling changes;
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responsibility for hazard identification and risk assessment of changes;
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identifying key safety performance indicators.
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161 The extent to which the guidance needs to be applied is a function of the risk associated with
the shared activities. Thus, before developing SMS interfacing arrangements, a risk assessment
must be undertaken by the parties involved. This may be a simple matter of making a judgement
about the degree of hazard and duration of activity.
162 It would seem to be potentially useful (with minor tailoring) for onshore application, particularly
where a significant element of core business activity is contracted out (eg maintenance).
Summary
163 Dutyholders should ensure that there is a suitable policy and procedure for managing
organisational changes.
164 Dutyholders should ensure that there is a suitable policy and procedure for retention of
corporate memory.
165 Dutyholders should ensure that they retain adequate technical competence and ‘intelligent
customer’ capability when work impacting on the control of major accident hazards is outsourced
or contractorised.
166 Dutyholders should ensure that suitable arrangements are in place for management and
monitoring of contractor activities.
167 Dutyholders should ensure that in addition to retaining intelligent customer capability, they
consider using industry guidance for interfacing safety management systems where core business
is contracted out.
168 HSE should consider reviewing its guidance
Managing contractors
HSG159 to ensure that
it is appropriate for major hazard sites and consistent with other relevant guidance (eg CHIS7) in
terms of requirements to maintain ‘intelligent customer’ capability. Guidance on SMS interfacing
between clients and contractors should also be considered.
Management of plant and process changes
169 Experience (for example the Flixborough disaster in 1974) has shown management of change
(MOC) to be an essential factor in the prevention and control of major accidents. This section
discusses plant and process changes. Management of organisational change is discussed under
‘Organisational change and management of contractors’ in this appendix.
170 Dutyholders should adopt and implement management procedures for planning and control
of all changes in plant, processes and process variables, materials, equipment, procedures,
software, design or external circumstances which are capable of affecting the control of major
accident hazards.
171 This approach should cover permanent, temporary, and urgent operational changes,
including control of overrides/inhibits, as well as changes to the management arrangements
themselves (see L111).
Guidance
172
Guide to the COMAH Regulations
L111 summarises the range of changes that should be
subject to management of change control procedures.