Management of Change

A critical aspect of laboratory safety is the implementation of a disciplined and documented Management of Change (MOC) process. Hydrogen safety training and lessons learned databases provide too many examples of incidents due to undocumented or un-reviewed changes in experimental equipment and processes, sometimes with disastrous results. Laboratory experimentation will naturally result in changes as personnel vary parameters in the normal course of research. A review of the safety plan and the hazard assessment is critical whenever even minor changes are made. The entire plan may not need be rewritten, but a review by the lab operator, the lab supervisor, and at least one outside expert should be conducted and documented to ensure that existing risks have not been increased or new risks introduced. Any safety questions raised in that review must be resolved before continuing operations. Periodic safety reviews as part of an organization’s safety culture and protocols also help identify and analyze changes and their potential risks.

Two typical situations arise in which poor MOC practices can cause big problems:

1. Long-term work by experienced personnel. It’s human nature that “familiarity breeds contempt” – if we’ve left safely at the end of the day for 100 days, it’s easy to assume that we will leave safely on the 101^st day as well, and we tend to stop questioning what’s around us.
2. Scale-up of experiments can dramatically increase the consequences of an incident. Any increase in the amount of hydrogen or other reactants requires special scrutiny. Where a release involving a few milliliters of hydrogen might be acceptably managed by the planned laboratory ventilation, for example, the release of hundreds of milliliters could overwhelm those systems, resulting in extensive damage and possible injury.

MOC processes are not only common sense for any lab dealing with potentially hazardous materials like hydrogen, they are also required by OSHA regulations in many cases. More information may be found at https://info.basicsafe.us/safety-management/blog/everything-you-need-to-know-about-management-of-change

Likewise, many tools are available for simplifying MOC, but the primary requirement is that changes be identified, documented, and evaluated specifically for any new or increased risks.