Part 3 - Oh My Goodness... We forgot about Change Control
Woo-hoo! It's finally site-wide internal audit
day. This is the day the EH&S Manager receives a laundry listing of outages to correct as identified by the members of the internal audit teams. Of course, these teams will find outages and then quickly pass them off to the EH&S department, not really caring what it takes to actually correct the items. But, that's OK, as the EH&S Manager is accustomed to this. It is just pleasing to know that they found the outages, before there was an incident where someone might be injured or there was property or product destruction.
As the EH&S Manager reads through the massive list of outages, something stands out, grabs their attention, and causes a slight panic attack. A spray bottle, of some sort of chemical, was being used in numerous production areas and the spray bottle was not labeled. The EH&S Manager investigated the outage, but could not identify who made a change or why the chemical was brought into the plant. No one could identify what the chemical was or how long it had been used.
Finally, after hours of investigation, it was determined that employees were told by someone in the Supply Room to use it for maintenance and general equipment cleaning. The EH&S Manager meet with the Supply Room attendant and learned that the chemical was a strong cleaning agent, had a very pleasant smell, and when mixed with water was a cheap and quick way to clean equipment. The Supply Room actually told the EH&S Manager they were under considerable pressure to reduce chemical costs and their operating budget. So, to meet the expectations of the site Leadership, they started identifying, selecting, and purchasing chemicals that were far less expensive, without informing anyone of doing so. Their job was to reduce costs and that is exactly what they intended to do.
The EH&S Manager immediately requested and received a Safety Data Sheet (SDS) from the vendor and reviewed the sections for health and safety hazards. Again, shock and disbelief surfaced with a mild panic attack. The SDS was clear that specific gloves were required for usage of the product. Without the specific glove type used as PPE, contact dermatitis was an evident health hazard along with several other health hazards. The EH&S Manager was certain that the employees were using the product without gloves as there were very few glove types offered at the plant and they did not have a lot of hazards. The EH&S Manager started the process to replace the new chemical with the previous chemical and remove all of the new chemical spray bottles in the plant.
Fast forward another day…The Plant Nurse calls the EH&S Manager into the Medical Clinic and explains there are numerous contact dermatitis cases being reported over the past 48 hours. The root cause is unknown. The symptoms are related to hand and finger skin redness, irritations, and some employees had moderate to severe blisters forming on their hands. Again, shock and disbelief surfaced with a mild panic attack by the EH&S Manager.
In the scenario above, the site did not have a robust Chemical Approval Process nor was the process included as part of the site’s Change Control. Departments were allowed to substitute chemicals at their discretion. SDSs were not obtained for new chemicals and there was not a review of the health and safety hazards.
A Chemical Approval Process, if it is well documented, robust, and followed by all employees, will eliminate the above scenario from ever occurring. Failure on a site’s part, not to have the Chemical Approval Process, will eventually be a headache for the EH&S, Medical, and Human Resource Departments. Most importantly, the health hazards to employees working with the chemicals is a risk the employer will never want to accept.
Furthermore, it is important to ensure that the Chemical Approval Process is a sub-set of your Change Control. For any new additions and/or changes to machinery, equipment, chemicals, processes, facilities, and grounds, the entire project should be subjected to Change Control.
Failure of a site to ensure clear-concise communication and 100% alignment on new chemicals, machinery, equipment, and processes will lead to negative consequences either short term or longer term.
The Chemical Approval Process and Change Control are 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 how to develop, implement, and sustain the Chemical Approval Process and Change Control, contact Billy Moore at 706-594-1660 and/or visit our website at www.strategicsafetyenvironmental.com/