It has long been the practice of companies working in the civil construction industry to be innovative and to encourage the workforce to participate in initiative schemes, from offering rewards for engineering solutions to solving issues around the capability of plant and equipment. Let's face it, there are very few pieces of kit out there in the marketplace that do exactly what we need them to do, and so there is always room for some improvement.
Things are much improved of course, but there is always the odd ‘tweak' that could be done to get around an obstacle or to reduce time on site and increase profit margins, and there it is right there - the driver of all improvements since the Industrial Revolution - profit.
However, times, as they say, are a-changing. Gone are the ‘back-of-a-cigarette-packet' drawings and sketches that we then expect our engineering workshops to create. Today's modern, sophisticated organisation will have in place a comprehensive procedure for looking at plant and equipment modifications.
Of course legislation - and the standard ISO9001:2015 section 8.5.6 - raises its necessary head requiring us to review and control changes, and retain documented information describing the results of the review, authorising the review and raising necessary actions arising from it. There is the common misconception that a change agreed among contract managers, designers, plant managers and fitters is ok, often with advice sought from the manufacturer and tests undertaken. However, a very important part of the process is missed. Documentation of the process, recording all the necessary elements that have led to the accurate assessment of the ‘change control', is a requirement. Good documented evidence will record the facts and ‘evidence' the process and the controls that lead us to believe that whatever changes are made are legitimate and arrived at without raising the risk level. The Health & Safety at Work Act (1974) too requires us, as an employer, to provide a safe system of work, and PUWER 1998 clearly considers change in the body of the regulation.
However, can we really be saving money or increasing profit margins by carrying out unplanned change? We must as an industry stop and consider the consequences of dealing with a fatality or serious injury through unplanned, unauthorised and unrecorded change. The loss or serious injury of a loved one through lack of planning is suffered all too often in our industry. We must consider management too, as through changes in the law one could potentially find themselves in jail under the Corporate Manslaughter and Corporate Homicide Act 2007. The financial implications of a huge fine to the organisation, if found to be in breach of the law, regulation or company procedure, could prove to be the undoing of years of good practice in other areas. Therefore, it is easy to see how financial and reputational damage to the organisation could prove damaging to all interested parties.
So, what can be done? The implementation of a procedure to challenge change must come from ‘risk-based thinking' through planning, review and improvement, as it makes us think ahead. Change control must be a preventative tool to establish sound, comprehensive, understandable and practical procedure and process, and not an interference or hindrance to improved practices. The idea is not to prevent change, but to control change.
Controlled, risk-based thinking leads to and builds upon embedded safety cultures, always asking those questions that prompt us to consider safe systems of work:
- Where will it be used?
- What will it achieve? (a safer system of work)
- Why do we need this change? (safety, wellbeing, efficiency, financial gain)
- How will we achieve it?
- Who will benefit?
The emphasis of how important it is to approach change must be understood, so that the organisation, the senior management and the workforce are as safe as can reasonably be expected, given that the change has been planned, recorded and signed off by qualified, responsible persons with the authority to do so. The ‘cigarette-packet' mentality must be a thing of the past, and the question we must all ask when considering overlooking change control procedures, with the inherent intention to save all of us from potential harm, is what if?
Simon Jackson is on the Training & Education Committee of the British Drilling Association (BDA)