HSE press release E167:03 - 16 October 2003
The Health and Safety Executive (HSE) has published a free information sheet for employers in major hazards industries looking at how to control safety risks in organisational change.
Organisational change and major accident hazards Chemical Information Sheet CHIS7 provides guidance on how to manage the impact of organisational change on their control of hazards. It is aimed primarily at on - and offshore, chemical and petrochemical industries, though operators of railways and nuclear installations may also find the information useful when involved in planning or implementing such changes to their business.
The guidance focuses on change at operational and site level, but is also relevant to changes at corporate level, which can have a significant impact on safety at operational level. The information sheet points to changes to roles and responsibilities, organisational structure, staffing levels and staff disposition as some of the changes that may have an effect on safety.
HSE inspectors have been concerned at finding weaknesses in the control of major hazards resulting from organisational changes across a number of industry sectors. In many instances organisational changes are not analysed and controlled, resulting in reduced defences against major incidents.
Chris Wilby, Head of HSE's Hazardous Installations Directorate, said: "Although organisational changes are a normal and increasingly frequent part of business life, businesses working in major hazard industries must take particular care to avoid risks to their employees and the public.
"Companies with major hazards must learn to assess and control the human and organisational risks of changes just as we assess and control engineering risks from plant changes. This guidance sets out, for the first time, a practical three step framework, which will help companies to identify and control risks and comply with health and safety law."
'Organisational change and major accident hazards', is available on the HSE website at: http://www.hse.gov.uk/pubns/chis7.pdf
1. For organisations operating offshore installations, relevant regulations include:
Duty holders must particularly consider whether, and how, organisational changes may impact on their safety management systems set out in their SCR safety case. Examples of more specific considerations include: arrangements for ensuring safe plant design under SCR and DCR; and effective emergency response under PFEER.
2. Operators of nuclear installations must hold a licence granted by HSE under the Nuclear Installations Act 1965. Licences have safety conditions attached, and breach of a licence condition (LC) is an offence. Of particular relevance to this guidance is LC 36. This requires licensees to "…make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety." It also requires that before implementation, the most significant changes must be submitted to HSE for agreement, with an adequately documented demonstration that risks will continue to be properly controlled, both during and after the proposed change.
3. Onshore major hazard sites in the UK (excluding nuclear and rail) come within the scope of the Control of Major Accident Hazards (COMAH) Regulations 1999, enforced by a joint Competent Authority (CA) comprising HSE, the Environment Agency (EA) and the Scottish Environment Protection Agency (SEPA). These Regulations require operators to: take "all measures necessary" to prevent and mitigate effects of major accidents to people and the environment; and to implement a major incident prevention policy including appropriate procedures and management systems. The CA can prohibit major hazard activities where they have concluded that there are serious deficiencies in these measures.
4. 'Top tier' COMAH establishments also have to submit a safety report to the CA for assessment which must be reviewed and if necessary revised whenever changes are made to the organisation that could significantly impact on the control of major incidents. Safety reports are assessed against criteria set out in the Safety report assessment manual.
5. Railway infrastructure controllers, station and train operators are subject to the requirements of the Railways (Safety Case) Regulations 2000. The safety case must demonstrate that the management system of the duty holder is adequate, and shall be revised "whenever it is appropriate" and "whenever required to do so by the Executive". HSE offers guidance that the safety case should be revised whenever "new activities or equipment or organisational changes are to be introduced". The changes must be accepted by HSE. Therefore duty holders must have a sound process for the management of organisational change.
All enquiries from journalists should be directed to the HSE Press Office
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