Part 2 - Oh My Goodness... We forgot about Change Control
Updated: Nov 29, 2017
At some point in time in our career, we have experienced the excitement (or controlled chaos) when a new machine arrived at the site. After weeks of installation and debugging, the machine was started in production and it directly led to an employee being injured.
And then we ask ourselves during the injury investigation, “How did everyone inadvertently overlook the machine safe guarding?", which was identified as an unsafe condition and the root cause of the employee being injured.
Machine safe guarding is often inadvertently overlooked during the design and planning stage for several possible reasons (typically more than one will apply)
1. The manufacturer assured us that they would meet all applicable machine safety
2. We assumed the manufacturer would include machine safe guarding in the build and
follow applicable standards
3. Decision was made to reduce some of the controls as this reduced overall project costs
3. Resources - no one understands the principles of machine safety at this site
4. The safety leader had no prior knowledge of the new machine - lack of communication
Machine Evaluation / Acceptance Trials for new equipment, machinery, and processes are required by sites to ensure:
1. What was designed and ordered by your engineers is what is being delivered
2. Production readiness and safe operation
3. Effectiveness of and compliance with machine guarding
Failure of a site to perform an on-site visit (at the manufacturer) to ascertain the production readiness and safe operation of the ordered equipment may present serious hazards which are risks that site might not be willing to take. All too often, a site will assume that the equipment manufacturer is knowledgeable of and following all applicable U.S. standards for the equipment build. We all know what happens when you assume. In addition, it is difficult and expensive to redesign guarding and controls, once the equipment has been shipped from the manufacturer.
The alignment of acceptance trials visits to equipment manufacturers should be based on costs of the project. For smaller projects, the risks maybe lower; however, for larger complex projects, more than one visit may be warranted to ensure the equipment build is progressing as designed and ordered. For a complex project involving machine safe guarding, ensure that at least one Machine Evaluation/Acceptance Trial has been completed at the manufacturer's location.
The site representative leading the acceptance trials must be well trained in machine safe guarding standards, techniques, and design. If the site does not have a trained representative, hire a qualified consultant to perform the Machine Evaluation/Acceptance Trial on behalf of the site. It is recommended that a site representative attend the Machine Evaluation/Acceptance Trial and work closely with the consultant in order to build their capability in machine safe guarding.
To ensure the Machine Evaluation/Acceptance Trial has been completed and documented, prior to the machine leaving the manufacturer, a robust and functional Change Control management system is required at the site. Change Control ensures any new machinery, equipment, and processes are reviewed and approved by the site’s Leadership Team. This should include Operations, Quality, HS&E, HR, Accounting, Supply Chain, Continuous Improvement, and Engineering. Failure of a site to ensure clear-concise communication and 100% alignment on new machinery, equipment, and processes will lead to negative consequences either short term or longer term.
Change Control is one of the main elements to achieving and sustaining zero defects in a manufacturing site. Documentation for this type of management system includes, but is not limited to:
1) Defining the business need
2) Scope of the work to be changed
3) Approval from site Leadership Team
4) Addressing rejected changes
5) Addressing recommendations/improvements
6) Recording changes in relevant policies, procedures, and work instructions.
For more information on Change Control and how to develop, install, and sustain this critical management system, contact Billy Moore at 706-594-1660 and/or visit our website at www.strategicsafetyenvironmental.com/