Dangerous Goods and Major Hazard Facilities Regulations

Guidance Note

Management of Change at Major Hazard Facilities Under the Dangerous Goods

(Storage and Handling) and Major Hazard Facilities Regulations
MHD GN-28 Rev 0 September 2001

Core Concepts
• Proper management of change is critical to control of safety at facilities storing and handling large
quantities of dangerous goods or other hazardous materials; there is clear evidence of this in
major incidents that have occurred in the past.
• The Dangerous Goods (Storage and Handling) Regulations 2000 and the Occupational Health
and Safety (Major Hazard Facilities) Regulations 2000 require the operator to manage their own
changes, whilst WorkSafe may audit, comment on, or require improvement to the operator’s
change management process.
• The operator is required to assess the hazards and risks of each change, and to ensure that
control measures will eliminate risk or (if not practicable to eliminate) will reduce risk so far as
practicable. Under the 2000 DG Regulations, these requirements encompass alterations to
premises, plant, processes and systems of work associated with dangerous goods; under the
MHF Regulations they encompass alterations to plant, processes, substances used, quantities of
Schedule 1 materials and the Safety Management System. There is little fundamental difference
between the requirements of the two sets of regulations, but the MHF regulations are slightly
more encompassing in scope.
• There are transitional arrangements between the previous and current DG Regulations:
− The requirement to assess hazards and risks of any change is immediate at all facilities that
store or handle dangerous goods. However, until 31 December 2001 compliance with Parts 4
to 12 of the 1989 DG Regulations is deemed to achieve compliance with the risk control
duties under the 2000 DG Regulations.
− Under Regulation 504(1) of the 2000 Regulations, operators of registered MHFs licensed
under the 1989 Regulations have had to submit to WorkSafe a written description of their
procedures for managing change in order to comply with Regulation 410.
− After submission of the written description, the operator must implement the procedures. For
some changes there may be a need to seek a licence amendment from WorkSafe.
• The types of change specifically governed by legislation increases from the 1989 DG
Regulations, through the 2000 DG Regulations, to the MHF Regulations. In addition, MHFs may
require a more robust change management, due to the potential for major incidents. Therefore,
operators of MHFs should critically review their existing processes, and make all practicable
improvements.
• Both the 2000 DG Regulations and the MHF Regulations include specific requirements to consult
with health and safety representatives, and to involve employees, in managing change.
• Contained in this Guidance Note are the “Critical Success Factors” for a management of change
process. These factors will be used as a basis for WorkSafe’s reviews of the management of
change procedures. The appendix to this Guidance Note provides additional discussion on what
may be considered good practice for change management at a major hazard facility.
 DG and MHF Regulations Page 2 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

1 Introduction and Purpose of This Guidance Note

This document provides guidance on management of Change under both the Dangerous goods
(Storage and Handling) Regulations 2000 and the Occupational Health and Safety (Major Hazard
Facilities) Regulations 2000.
The purpose of the guidance is to amplify the objectives of the Regulations, to identify the general
issues that should be considered, and to provide practical examples to illustrate the concepts and
potential approaches. It is not the intention of the guidance to provide detailed approaches or detailed
regulatory assessment criteria for this subject.
Guidance Notes indicate what is explicitly required by the Regulations, discuss good practice and
suggest possible approaches. An explicit regulatory requirement is indicated by the word must, other
cases are indicated by the words should, may, etc. WorkSafe acknowledges that what is good
practice, and what approaches are valid and viable, will vary according to the nature of different Major
Hazard Facilities and their inherent hazards.
This Guidance Note does not purport to be a comprehensive statement on all or any provision
of the Regulations. The document necessarily contains matters of interpretation and policy
and is not exhaustive. The document is not a substitute for detailed advice on the Regulations
or the Acts under which the Regulations have been made.

2 Why is Management of Change Needed?

Failure to properly manage changes to a hazardous facility can significantly increase the risk of major
incidents. This is clearly indicated by experience such as:
• Flixborough, England. On 1 June 1974, a release and explosion of cyclohexane occurred at a
caprolactam production plant near Flixborough. 28 workers were killed and 36 injured. Hundreds
of people off-site were injured, 53 sufficiently seriously to be recorded as casualties. Around 2000
residential and commercial properties were damaged over a wide area.
The Court of Inquiry concluded that “the disaster was caused by the introduction into a well
designed and constructed plant of a modification which destroyed its integrity”, specifically that
temporary piping to bypass a reactor vessel had been inadequately designed, manufactured and
supported. A further contributing factor was that the plant management organisation had
undergone substantial change, with the result that suitable people were not available to assess
engineering changes as they were being proposed.
• Bhopal, India. On the night of 2/3 December 1984, there was a runaway reaction between water
and methyl-isocyanate in a storage tank at a MIC derivatives plant, ultimately resulting in a release
to atmosphere of several tonnes of MIC, which is highly toxic. The precise numbers of dead and
injured are not known, but acute fatalities numbered at least 2000.
The cause of the accident appears to have been water entering via a jumper line that had been
installed without following the company’s management of change process. In addition, certain
protective systems that could have limited the consequences of the incident had been disabled;
proper management of change should have identified the hazards associated with this. Finally, the
extreme number of fatalities was in part due to uncontrolled growth of population immediately
surrounding the facility.

A clear benefit of formal, robust management of change is that it ensures that potential new or changed
hazards are identified and dealt with before they arise. As a consequence, both the Dangerous Goods
(Storage and Handling) Regulations 2000 and the Occupational Health and Safety (Major Hazard
Facilities) Regulations 2000 include specific requirements for management of change.
 DG and MHF Regulations Page 3 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

3 Summary of Regulatory Requirements

The 2000 DG Regulations prohibit use of “new” premises, plant, Definition under 2000 DGR
processes and systems of work until hazards have been identified, New: Not previously used in the
risks assessed and adequate control measures put in place to storage and handling of
eliminate risk, or if it is not practicable to eliminate, reduce it so far dangerous goods, or previously
as practicable (Regulation 410). The Regulations also require used but about to be altered in a
manifests, placarding, fire-protection systems, emergency plans and way that ought reasonably to be
material safety data sheets to be updated in-line with any change to expected to create a new hazard
or a different level of risk.
the facility (Regulations 427, 432, 436, 437 and 438).
The regulatory requirements may apply to changes in the type and quantity of Dangerous Goods,
changes in the activities performed, and changes to procedures and organisation. Although not
explicitly stated in the Regulations, “processes and systems of work” include all these factors.

The MHF Regulations require the operator of an MHF to have in Definition under 2000 MHFR
place a system for planning modifications to the facility, and to Modification: any changes or
include a description of this within the safety management additions of plant, processes, or
system (Schedule 2, item 5). substances used (in particular
Before making any modification to the facility, the operator of an Schedule 1 materials), or a change to
the safety management system,
MHF must review (and if necessary revise) the identification of which creates a hazard not
hazards, the assessment of safety and the adoption, previously identified or increases the
implementation and monitoring of control measures (Regulation risk from potential major incidents.
306(2)).
Following modification to the facility, the operator must review/revise the SMS (Regulation 301(5)), and
must review/revise the Safety Case if control measures have been revised (Regulation 404(1)).
Descriptive material in the Safety Case (as required under Schedule 4) would need to be maintained
current.
Under the MHF Regulations, the phrase “plant, processes or substances used, … or the SMS” should
be taken to include a wide range of types of change. These may include: the type or quantity of
dangerous goods; the activities performed involving or potentially impacting those goods; related
buildings, plant or equipment; operational or maintenance procedures; control, alarm or trip system
software or calibration; the organisational structure or staffing; or individual’s roles and responsibilities.

4 What Constitutes a Change?

In principle, the definition of change for the purpose of the Regulations should include anything having
potential to alter hazards or the level of risk at the facility. This should not be limited to physical
changes, but should include changes to management systems, procedures, organisational structure
and personnel. The two major incidents cited at the beginning of this Guidance Note bear this out, as
they involved physical changes to process plant, changes to management organisation, disabling of
safety systems, and uncontrolled residential construction in surrounding areas.
The table below provides examples of the range of circumstances that may be considered a “change”
in this context, and may therefore require formal management.

Examples of Changes that may need Formal Management

• Introduction of new dangerous goods or other hazardous materials
• Re-introduction of particular dangerous goods or hazardous materials after a period of absence
• Alteration of the activities performed (eg the chemical process technology) involving these materials
• Increase in the quantity of dangerous goods or hazardous materials held on-site
• Addition of new processes, buildings, plant and equipment
• Changes in the design and construction of existing processes, buildings, plant and equipment
• Introduction of temporary processes, buildings, plant or equipment
 DG and MHF Regulations Page 4 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

• Increase or decrease in throughput of the facility

• Temporary or permanent shutdown of the facility, or a section of it
• Re-start of the facility, or a section of it, after an extended period shut-down
• Changes to the codes and standards applying to the facility
• Changes to available knowledge of technical and operational safety issues
• Changes to the content of management, operating, maintenance, engineering or emergency procedures
• Variances from established management, operating, maintenance, engineering or emergency procedures
• Changes to the frequency or nature of safety-critical activities (eg maintenance)
• Changes to organisational structure, such as de-manning, out-sourcing, or relocation of personnel
• Redefinition of the roles and responsibilities of safety-critical personnel
• Changes to the persons filling safety-critical positions
• Introduction of a new contractor group
• Reconfiguration or reprogramming of control and monitoring systems
• Alteration to the range of an instrument transmitter
• Changes to the set-points of alarm, shut-down systems, safety/relief valves, etc
• Redefinition of the facility’s critical operating parameters (COPs – see GN10)
• Bypassing or defeating of control measure (ie. shutdown valves etc)
• Changes to land-use around the facility
• Changes to other facilities nearby or connected by pipeline or other means

Operators should develop a comprehensive definition of what is considered a change in the context of
the specific MHF, and develop the change management processes based on this definition. Any
proposed activity should then be compared to the definition, to determine whether the proposal is a
change that will require management under the defined processes

5 Who Should be Involved in Reviewing a Proposed Change?

There are legislated requirements under the OHS Act to consult with the workforce prior to making any
change to the workplace. In addition, both the 2000 DG Regulations and the MHF Regulations include
specific requirements to involve employees (including contractors) and to consult with their health and
safety representatives (HSRs) in identification of hazards and assessment of safety. Therefore
employees, contractors and their HSRs must be involved in the management of change process.
It should also be noted that both the DG and MHF Regulations require consultation with the emergency
services in the event that the proposed change requires a revision to the fire protection systems or
emergency plan at the facility.

6 The Written Description of Management of Change Procedures

The written description of the management of change process should include copies of the operator’s
procedures for identifying, reviewing, and approving all type of change, together with copies of
documents referenced by these procedures. The procedures should cover the elements referred to in
the Critical Success Factor table within this Guidance Note. These other documents may include
check-lists for the review processes, the HAZOP Study procedure, a list of delegated responsibilities in
relation to change, and position descriptions of key personnel involved in change review. Information
should be sufficient for WorkSafe to form a view as to whether or not the operator’s management of
change process is adequate in the context of the specific facility, its hazards and risks.
The MHF Regulations require operators to be committed to continuous improvement so it is anticipated
that over time changes will be made to procedures to improve their effectiveness. In order to ensure
continued compliance with Regulation 504(2) of the 2000 DG Regulations operators are required to
resubmit their procedures if changes are made to the substance1 of the procedures.

1
A change of substance is, for example, a change in content or methodology of the procedures submitted. Editorial or
formatting changes would not be considered to be a change of substance.
 DG and MHF Regulations Page 5 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

The 2000 DG Regulations do not require WorkSafe to approve the operator’s management of change
processes, but WorkSafe has the power to direct or require changes if necessary in order to ensure
compliance with Regulation 410. WorkSafe is likely to audit the operator’s compliance with the
submitted or altered management of change process, and may do so at any time after its submission.
If WorkSafe detects non-compliance by the operator with the submitted or altered management of
change process, it will take appropriate action.
Also, operators should note that an MHF licence will not be granted until WorkSafe is satisfied that the
applicant has (amongst other things) complied with Part 3 of the MHF Regulations and prepared a
Safety Case in accordance with Regulation 402 of the MHF Regulations. In turn, Part 3 requires the
operator to include a description of the management of change process within the SMS, and to use the
SMS as the primary means of ensuring safe operation. Management of change is an important control
measure, and Part 3 also requires the operator to justify the adopted control measures. Hence a
robust documented management of change process, which is implemented in practice, is a vital
aspect of the Safety Case.
Changes or alterations that are to be managed under Regulation 410 of the 2000 DG Regulations are
wider in scope than those covered by Regulation 208 of 1989 DG Regulations. The definition of
“modification” under the MHF Regulations is wider still. Therefore, the management of change process
required to be in place by the time the Safety Case is submitted to WorkSafe may need to be
significantly more comprehensive than the previously existing process.
Finally, the MHF Regulations require the operator to comply with the provisions of Parts 3, 5 and 9 so
far as practicable, during the period up to end of 2002. Therefore operators of MHFs should critically
review their current management of change processes, and initiate any improvement that may be
considered necessary, at the earliest possible date.

7 Compliance and Verification

The 2000 DG Regulations require any application for a DG licence under Regulation 503 to include
information that demonstrates compliance with the Regulations (Schedule 6). Up to 31 December
2001, compliance may be demonstrated with either the risk control duties of the 2000 DG Regulations
(hazard identification, risk assessment and risk control measures) or with Parts 4 to 12 of the 1989
Regulations. From 1 January 2002, compliance must be demonstrated with the risk control duties of
the 2000 Regulations.
Demonstration of compliance with Parts 4 to 12 of the 1989 Regulations requires:
• A summary of the steps taken or to be taken that demonstrate that the applicant is acting in
accordance with Parts 4 to 12 of the 1989 Regulations; and
• A description of how the applicant will verify compliance with Parts 4 to 12 of the 1989 Regulations.
Demonstration of compliance with the risk control duties of the 2000 Regulations requires:
• Information that demonstrates the adequacy of the applicant’s risk management process, including
a summary of the steps taken or to be taken in relation to hazard identification, risk assessment and
risk control measures;
• Information that demonstrates the adequacy of the risk control measures; and
• A description of how the applicant will verify compliance with the risk control duties (Divisions 3 and
4 of Part 4).
Thus, for a licence renewal application under the processes of the 1989 Regulations, the applicant will
need to show how the facility as it currently exists complies with each and every relevant clause in
Parts 4 to 12, perhaps by a tabular cross-check. It will also be necessary to show how this level of
compliance will be maintained in the longer-term.
For a licence renewal application under the processes of the 2000 Regulations, the applicant will need
to show that there are robust mechanisms to initiate the necessary hazard identification and risk
assessment, and that the hazard identification and risk assessment procedures are valid. The
applicant will also have to show how the risk control measures meet the requirement to eliminate risk or
reduce it so far as is practicable. Finally, it will be necessary to show how compliance will be
 DG and MHF Regulations Page 6 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

maintained in the longer-term. This would typically be achieved by setting appropriate performance
indicators and standards for the activities, and by tracking performance through monitoring and
corrective action systems.
In principle it will be possible for a facility to be partially in compliance with the 1989 Regulations and
partially in compliance with the 2000 Regulations, up to 31 December 2001. In such cases, both sets
of information would be required.

8 Critical Success Factors

WorkSafe’s assessment of the operators’ management of change processes will include consideration
of the following “critical success factors”:

Critical Success Factors for Management of Change Processes

• “Change” is properly defined in the context of the specific facility
• The definition includes all relevant types of change, physical, operational, procedural, organisational, etc
• All changes are reviewed and assessed before being implemented
• Reviews are conducted by suitably knowledgeable and experienced people
• Reviews are based on auditable criteria, triggering detailed assessments as necessary
• Detailed assessments are conducted by suitably knowledgeable and experienced people
• Detailed assessment includes identification of hazards, and assessment of safety
• Each change is checked for compliance with Regulations, codes and standards, and to ensure adequate
systems are in place for continuing compliance (verification activities)
• Control measures are altered in line with changes, to ensure risks remain reduced so far as is practicable
• Maintenance, performance indicators and performance standards are established and monitoring and
corrective actions are effected for all control measures altered / implemented as a result of the change
• Reviews and assessments are properly recorded. Decisions are transparent and formally accepted
• The process allows for consultation with employees and other affected workers, and the emergency
services (where appropriate)
• QA and QC processes are applied throughout each change project
• Knock-on changes to drawings, procedures, work instruction, the Safety Case etc are fully implemented
• Necessary instruction and training in the change takes place
• Changes are reviewed after implementation to ensure that the control measures perform as intended, and
there is an “improvement loop”
• The change management system is monitored and reviewed to an established schedule
• Processes exist for rectifying any deficiencies noted during monitoring and review
• There is routine monitoring for incremental, unintentional and external changes
• There is routine monitoring of temporary changes, to ensure timely reversal

Appendix 1 to this Guidance Note provides more detailed advice on what may be considered to
constitute good practice for management of change at MHFs and other facilities storing and handling
large quantities of dangerous goods.
DG and MHF Regulations Page 7 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

9 Bibliography

The following are recommended as sources of general information, which may be useful in addition to
the information provided in this guidance note. However, it is important to note that these documents
have not been written specifically as guidance on how to comply with the duties under the Regulations.
Copies of the referenced documents may be viewed in the WorkCover Library at 222 Exhibition Street,
by appointment (telephone 9641 1548).
1. NSW Department of Planning (1995). Hazardous Industry Planning Advisory Paper No 9:
Guidelines for the Development of Safety Management Systems. ISBN 0 7310 3062 6.
2. American Institute of Chemical Engineers, Center for Chemical Process Safety (1992): Plant
Guidelines for Technical Management of Chemical Process Safety. ISBN 0 8169 0499 5.

For more information regarding this Guidance Note, contact the Major Hazards Division at the Victorian
WorkCover Authority (telephone 03 9641 1528, e-mail mhunit@workcover.vic.gov.au).
 DG and MHF Regulations Page 8 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

Appendix 1
Good Practice for Management of Change
This Appendix is provided for information to operators of MHFs and of other potentially hazardous
facilities. It is not guidance on the content of the DG or MHF Regulations, but describes what can be
considered to be good practice for management of change at hazardous facilities.

What should be Considered to Constitute a Change?

Change should be properly defined in the context of the specific facility. For example, alterations in
storage tank level should not need formalised control, but should be administered under operating
procedures. However, storage of a product that has not been held in that tank previously/recently
would need to be controlled as a change. In addition, changes to the relevant operating procedure
would require formal control, as would any changes to high/low level alarm points, critical operating
parameters (COP), and trip settings, if outside of previously agreed ranges.
The definition of change should include all changes that have the potential to introduce new hazards, or
to change the risk from existing hazards. This does not simply include physical changes, and will most
likely include procedural and organisational changes also. Examples of changes that may require
formal management have been listed in the table below.

Examples of Changes that may need Formal Management

• Introduction of new dangerous goods or other hazardous materials
• Re-introduction of particular dangerous goods or hazardous materials after a period of absence
• Alteration of the activities performed (eg the chemical process technology) involving these materials
• Increase in the quantity of dangerous goods or hazardous materials held on-site
• Addition of new processes, buildings, plant and equipment
• Changes in the design and construction of existing processes, buildings, plant and equipment
• Introduction of temporary processes, buildings, plant or equipment
• Increase or decrease in throughput of the facility
• Temporary or permanent shutdown of the facility, or a section of it
• Re-start of the facility, or a section of it, after an extended period shut-down
• Changes to the codes and standards applying to the facility
• Changes to available knowledge of technical and operational safety issues
• Changes to the content of management, operating, maintenance, engineering or emergency procedures
• Variances from established management, operating, maintenance, engineering or emergency procedures
• Changes to the frequency or nature of safety-critical activities (eg maintenance)
• Changes to organisational structure, such as de-manning, out-sourcing, or relocation of personnel
• Redefinition of the roles and responsibilities of safety-critical personnel
• Changes to the persons filling safety-critical positions
• Introduction of a new contractor group
• Reconfiguration or reprogramming of control and monitoring systems
• Alteration to the range of an instrument transmitter
• Changes to the set-points of alarm, shut-down systems, safety/relief valves, etc
• Redefinition of the facility’s critical operating parameters (COPs – see GN10)
• Bypassing or defeating of control measure (ie. shutdown valves etc)
• Changes to land-use around the facility
• Changes to other facilities nearby or connected by pipeline or other means

Depending on the nature of the facility, and on the overall structure of the operator’s organisation and
management system, it may be necessary to control different types of changes through slightly differing
processes. For example, changes might be grouped as follows:
• Changes to dangerous goods and other hazardous materials in storage and use
• Changes to regulations, codes and standards, or to technical or operational safety knowledge
 DG and MHF Regulations Page 9 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

• Changes to engineering design, process technology or process operations

• Changes to organisational structure, to staffing, or to personnel roles and responsibilities
• Changes to procedures, or variances from established procedures
• Changes to control and shut-down systems’ software
• Temporary bypass or defeating of alarm and trip systems
• Abnormal operations
However, this would need careful consideration, to ensure a consistently robust approach, and to
ensure that all necessary persons were involved in reviewing each type of change.
Like for Like Replacement
Replacement of equipment by an identical item (“like for like” replacement) may not need to be
considered a “change” in this context. However, the operator should carefully define what is
considered “like for like” replacement, as equipment of similar configuration may have a different
detailed specification (eg a new model of pump may have a higher discharge pressure). This aspect of
the change management process should be reviewed regularly.

How can Changes be Identified?

It is particularly important to prevent informal changes from occurring, either individually or in
cumulation. Unless all changes are formally identified as such, they cannot be properly controlled.
For changes originating within the facility or the operator’s organisation, this can be addressed by
requiring all proposed changes to be formally requested, via a standard procedure and form. Persons
can be introduced to the procedure and form at the time of induction, and subsequently trained in the
process. It is necessary to ensure that employees understand the basis for the facility’s design and
safe operation, so that they are capable of recognising a relevant change, for this process to work. It is
also important that personnel are alert for and have systems in place to ensure that incremental change
doesn’t occur.
It may be more difficult to identify changes external to the facility, as it will require either that third-
parties reliably notify the operator of all relevant changes, or that the operator periodically requests the
necessary information. The possibility of some types of external change may be minimised, but not
necessarily eliminated, by suitable contractual arrangements. Examples of external changes that may
affect hazards and risks at the facility include:
• Alteration to the quality of a feedstock, including trace materials
• Change in truck drivers used to deliver feedstock
• Change in capacity of transfer pumps at an upstream plant
• Changes to the location, manning or resourcing of the local emergency services
• Changes to the capacity or reliability of the towns water supply or grid electricity supply
• Construction of new residencies or creation of other sensitive land uses near to the facility
• Addition of plant or other changes to the risk profile of an adjacent facility.
• Changes to emergency response arrangements at an adjacent facility

Managing Urgent Changes

It has to be recognised that there may from time to time be a requirement to make urgent changes, eg
to prevent a major incident from occurring, or to prevent serious loss of production or serious loss of
product quality. In such cases it may be undesirable to delay the change for official review and
assessment. However, the change should nonetheless be reviewed and assessed as soon as possible
after implementation, and only then formally adopted. In fact, the change should be reviewed and
assessed even if it has already been reversed, as the change may have had potentially undesirable
outcomes, and it is necessary to identify a better solution to any such “emergency” that may arise in the
future.
Operators need to carefully consider the parameters controlling what changes can be allowed, and how
this can be built into the management of change process. eg. what changes can be made “on the run”
and what changes will require a shutdown.
 DG and MHF Regulations Page 10 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

There may be benefit in linking the management of change process with the permit-to-work system.
Persons administering the permit-to-work system could then check with the management of change
system records, to confirm that work requests only relate to changes that have been properly assessed
and duly authorised.

Who Should be Involved in Reviewing a Proposed Change?

There are legislated requirements under the OHS Act to consult with the workforce prior to making any
change to the workplace. In addition, both the 2000 DG Regulations and the MHF Regulations include
specific requirements to involve employees (including contractors) and to consult with their health and
safety representatives (HSRs) in identification of hazards and assessment of safety. Therefore
employees, contractors and their HSRs must be involved in the management of change process.
Representatives of all relevant and affected groups should be involved in the review of all significant
proposed changes. The persons who should be involved may vary from case to case, but in general
should include representatives of the safety, operations, maintenance and engineering departments.
Prior to this, there may be merit in using a committee or “oversight” process to ensure that each change
is briefly reviewed as it is proposed. This initial review would determine, via a formally established rule-
set, whether there is a need for more detailed review, and would identify the persons who should be
involved and/or consulted.
Reviews of proposed changes should involve personnel of a seniority reflecting, not only the scale of
the change project, but also the level of the associated hazard and risk.
It should also be noted that both the DG and MHF Regulations require consultation with the emergency
services in the event that the proposed change will require a revision of the fire protection or
emergency plan at the facility.

What Factors should be Considered when Reviewing a Proposed Change?

Where there is a potential for a change to alter the hazards and risks at a facility, the management of
change process should trigger review of the hazards, risk and control measures, as well as any
engineering or other reviews. The decision to instigate or not instigate such reviews should be taken
by a senior person or persons, and sign-off should be required of all decisions. The decision should be
based on auditable criteria, such as whether the change would affect a process and instrumentation
diagram (PID), in which case a Hazard and Operability (HAZOP) study or the like would be requested.
Specific factors to be considered in the reviews should include:
• Has risk associated with the storage and handling of dangerous goods been eliminated or (if
it is not practicable to eliminate risk) reduced so far as is practicable?
• Is the change necessary, or can an alternate be found that does not introduce new hazards, or
does not increase the risk of existing hazards, or results in a lesser risk increase?
• Is the proposed change in compliance with the applicable regulations, codes and standards?
• What measures / systems will be required to ensure continued compliance?
• What specifically are the new hazards that are introduced? What is the increase in risk?
• What control measures are required?
• What changes to the SMS are necessary (procedures, personnel, organisation etc)?
• What changes are necessary to Notifications, Licences or the Safety Case?
• What changes are necessary to drawings, procedures and to other documentation?
• What are the constructability issues for new buildings, plant and equipment?
• What are the new maintenance requirements, and are there operability issues?
• What are the new inspection and test requirements?
• Does the holding of spares and consumables need to change?
• What additional or changed education and training is necessary?
The reviews should consider not only the change in itself, but also the impact the change may have on
other areas, processes, plant, equipment, people and procedures.
 DG and MHF Regulations Page 11 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

The format for the review should reflect the nature of the facility, the nature and severity of its hazards
and risks, and the nature of the proposed change in relation to the hazards and risks.
Thus, for example, a change to chemical process plant that requires alteration to PIDs would typically
be subject to a Hazard and Operability (HAZOP) study, amongst other reviews. Likewise, a change to
a feedstock of a chemical process plant would also be subject to HAZOP study. However, HAZOP
study would probably not be useful as a means of reviewing changes to drum storage of dangerous
goods at the same facility. Other methods may be more appropriate in such cases, eg What-If Studies.
For consistency, the operator should consider using the same processes for review of hazards and
risks as part of managing changes, as they do for input to the Safety Case. Records of the reviews
should be kept, including in particular records of any hazard identification and safety/risk assessment.

Agreeing or Rejecting a Proposed Change

There should be formal criteria for accepting or rejecting change, which should in particular include
consideration of hazard and risk, as well as any impact on production rates, quality, costs, etc. There
should be a feedback mechanism to inform personnel that raised the initial change request, or the
issue that lead to the change, of the action that will be taken.
Safety criteria could be based on risk assessment using a “risk matrix” method, for example, or on
quantitative risk criteria. Such criteria should be consistent with the regulatory requirement to eliminate
risk or reduce it so far as practicable, and also consistent with any criteria being used in development of
the Safety Case for the facility.
Decisions should be transparent, and should be agreed and signed for at an appropriate senior level in
the organisation. In no case should the decision process allow acceptance of any change that violates
the fundamental duties on the operator under the OHS and DG Acts.

Implementing a Proposed Change

Necessary changes to documentation and drawings should be drafted before any change is
implemented; this may include changes to process drawings, process descriptions, safeguarding
memoranda, etc, and also changes to the hazard identification, safety assessment, safety management
system, emergency plan, and Safety Case as necessary. The drafted changes can be agreed and
signed, and then introduced concurrent with the change itself being made.
All personnel affected by the change should be provided with training in respect of the change.
Sufficient people should be trained in advance of commissioning the change, to ensure safe initial
operations. Any remaining training should follow immediately after the change. This minimises the
potential for confusion between the status of the facility and the status of training, whilst ensuring there
are always people available who have been appropriately trained.
Prior to commissioning, a check should be made that the change has been implemented as intended.
Normal commissioning checks should also be carried out, including checks that all actions arising from
safety, operability and other reviews have been satisfactorily closed-out. In addition, checks should be
made that the control measures their required performance. Compliance with legislation, the design
intent, and actions arising during the change project, should all be formally “signed-off’”.
Where changes are cancelled or reversed, it will be necessary also to cancel or reverse changes to
procedures and the SMS. Persons trained in the change should be formally notified that the change is
to be cancelled / reversed. Reversing any change may need to be treated as a change in itself.

Documenting the Change

A log of changes should be maintained, and detailed records kept of each change, including any that
have been reversed. The records should include at least the following information:
• The reason for proposing the change
• Records of all reviews and assessments of the proposed change
• Records of who authorised the change, and when
• Records of changes made to the change, and the approval of these
• Records of any pre-commissioning checks, with formal sign-off
 DG and MHF Regulations Page 12 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

• Clear records of when the change was commissioned, i.e finally “made”
• Clear records of when the change was reversed (if applicable)
• “Before and after” copies of all affected drawings and documentation
It is also appropriate to retain records of changes that were proposed, but did not proceed. This may
be used to assist in management of future proposed changes. Where such proposed changes relate to
hazard and risk control measures, this information may be useful in support of the “demonstration of
adequacy” that is required under the MHF Regulations.

Managing the Documents

A related issue is document control of engineering drawings, operating and maintenance procedures,
the SMS, the Safety Case etc. As changes are made to these documents, it is important that either:
• All superseded versions are withdrawn from use; or
• All controlled versions are updated, whilst all other versions are marked as “not controlled”.
Operators should be aware of legal requirements related to retention of records.

Managing the Quality of the Change

There is a clear link between management of change and management of quality. If the change that is
actually implemented is not what was intended and/or is not what was reviewed, then the agreed
acceptability of the change, or the agreed control measures, may be invalid. In such cases the quality
of management of the change project has been deficient. Reviews of such projects should include an
investigation of why the change process failed (eg. was the technical governance process inadequate)
to prevent a recurrence. Therefore quality management principles should be robustly applied to all
changes, whether engineered, written, operational or organisational.
Further, it is an observed fact that many management of change forms are poorly completed by front-
line supervisors/engineers; organisations need to conduct regular comprehensive QA/QC audits of their
activities under their own management of change processes.

Temporary Changes
Temporary changes may include, for example, bypassing of alarm devices where these have failed, or
where their alarm settings are being exceeded frequently during an extended period of abnormal
operations. They may also include, for example, installation of temporary equipment, such as a
portable generator or pump being used whilst permanent equipment is being maintained or repaired.
Temporary changes require management just as much as permanent changes, even though it may be
possible to accept lower levels of engineered control measures for short-term changes than for long-
term changes, provided additional controls are enacted (ie. the change is closely monitored).
The management of change system should carefully distinguish between permanent and temporary
changes, and should have checks in place to prevent changes becoming permanent without thorough
review when those changes were intended only to be temporary.
There should be limits set to the allowable duration that a temporary change may be in place, as some
temporary changes may increase risks in a manner that is tolerable in the short-term but not tolerable
in the longer-term.
Careful consideration should be given to how best to record the nature of temporary changes, in
drawings, manuals, procedures etc. For short-term changes document updates may be unnecessary,
but formal document update may be required for changes that exist for extended periods.

Review and Feedback

There will be benefit in reviewing changes after implementation. This is an important part of the
process of continual improvement. Questions that may be asked during such reviews include:
• Has the change proceeded as originally intended, or has the change itself changed? If so, the
implications for safety will not be completely understood, and the hazard identification, safety
assessment and control measures should be reviewed again.
 DG and MHF Regulations Page 13 of 13 WorkSafe MHD
Guidance Note Management of Change September 2001

• Did any unexpected hazards arise during implementation of the change? If so, these hazards
should be assessed, their nature and possible implications recorded, and the information
communicated to persons who need to know and who are able to take action to rectify the situation
and prevent repetition.
• Has the change achieved the desired effect? If it has not, and there are new hazards introduced or
risk has increased, then consideration should be given to reversing the change.