Perhaps a better way
The Contra Costa County (Calif.) Safety Council described requirements for OSHA covered processes to have a Management of Organizational Change program; with the main requirements in their ordinance cited in Chapter 7: Management of Change for Organizational Changes:
- 7.1 Forming a “Change Team” or “MOC Team;”
- 7.2 Defining the Existing Situation and Identifying Affected Areas;
- 7.3 Developing the Technical Basis for the Change;
- 7.4 Assessing the Impact of the Organizational Change on Safety and Health; and
- 7.5 Completing the Management of Change.
Most companies using the checklist can claim they have met the requirements of Sections 1, 4, and 5. The struggle begins with Sections 2 and 3 that are at the heart of the MOOC process. The U.K. Health and Safety Executive (HSE), the equivalent of OSHA, invested research into understanding MOOC from a best practice perspective. Part of this research involved studying how console operators deal with organization pressure:
Kecklund and Svenson (1997) asked control room operators to report on the strategies they use to maintain their performance. Operators stated they use the organization as a resource when coping with more demanding work situations such as arise during outages, by handing over tasks to others, postponing activities to the next shift, etc. They also judge that organizational factors, such as planning and shift change, had a bearing on misinterpretation errors. They also indicated lack of education, experience and knowledge as important contributor’s to misinterpretation errors, underlining the value of training. 
Reviewing known methodologies, the Executive concluded that what was required was a two-part analysis. The first step would be an investigation of the needs of the new organization compared to the old one. The next step would look at the capabilities required of each position. Working through selected fault trees will aid in evaluating these job positions.
The cast of characters for this study is similar to a PHA team. A trained chairperson is needed to steer the discussion. The review starts with the management system overview using a ladder assessment to review organizational factors. The dotted line represents the boundary between acceptable and unacceptable practices (Table 1).
Table 2. Defining how your operators spend their time is a first step in establishing workflow. (Click to enlarge.)
There are 12 ladders in total; the following are considered to be key performance requirements of process control operators:
- Be able to follow the condition of the process, anticipate its behavior and hence, select an appropriate control strategy (i.e., have high ‘situation awareness’);
- Be in a fit state to monitor the process (i.e., be awake and attentive);
- Be willing to take action as and when necessary; and,
- Be able to take action, reliably and within the necessary time frame.
In addition, key team performance requirements are:
- Be able to collect and share critical information about the process and control actions; and,
- Be able to co-ordinate actions.
The review identifies many factors that influence the operator and team performance, including (in alphabetical order):
- Culture (e.g., openness, team spirit);
- Interactions with other activities (e.g., disturbances);
- Management of change;
- Number of staff;
- Procedure design;
- Process control technology;
- Roles and responsibilities;
- Training; and,
- Working hours (including shift pattern) .
In practice we have found it takes a couple of days to fully train a team. Once the team starts doing the management assessment we have found collecting evidence was the biggest time constraint and having experienced people in the room allowed for quick identification of issues. The expectation was that a site’s management system should be common for all units, but in practice we found differences. We also had to arrive at a compromise between an operator’s perception of a system and a supervisor’s view. However, once the ladder assessment was complete it was common for all the job posts being reviewed.
The physical assessment
The physical assessment tests the staffing arrangements against six‘’:
i) There should be continuous supervision of the process by skilled operators, i.e., operators should be able to gather information and intervene when required;
ii) Distractions such as answering phones, talking to people in the control room, administration tasks and nuisance alarms should be minimized to reduce the possibility of missing alarms;
iii) Additional information required for diagnosis and recovery should be accessible, correct and intelligible;
iv) Communication links between the control room and field should be reliable. For example, back-up communication hardware that is non-vulnerable to common cause failure should be provided where necessary. Preventive maintenance routines and regular operation of back-up equipment are examples of arrangements to assure reliability;
v) Staff required to assist in diagnosis and recovery should be available with sufficient time to attend when required;
vi) Operating staff should be allowed to concentrate on recovering the plant to a safe state. Therefore distractions should be avoided and necessary but time consuming tasks, such as summoning emergency services or communicating with site security, should be allocated to others.