Change management in OSH

What is change management in safety and health?

In occupational risk prevention, a change is any modification to working conditions that may alter existing hazards, worker exposure, or the effectiveness of control measures. Change management is the organizational process that detects these modifications in advance, requires their preventive analysis before implementation, and subsequently verifies that the planned measures are effective. It is not a new discipline nor a specific procedure within Spanish regulations; rather, it is the systematic application of existing obligations, particularly the requirement to review risk assessments when working conditions change.

The concept originated in industrial process safety, where an unanalyzed modification to a valve, flow rate, or operating sequence can trigger serious accidents. Over time, it has spread to any organization through ILO guidelines on occupational safety and health management systems and management standards, which include change management as an element of a preventive system.

In Spain, the legal basis is twofold. Law 31/1995 mandates that the initial risk assessment be repeated when selecting work equipment, chemical substances or preparations, introducing new technologies, and modifying workplace layouts, and that it be updated whenever working conditions change. Royal Decree 39/1997 specifies that the assessment must be extended to these situations and reviewed when damage is detected or when controls show that the measures are inadequate. Managing change means organizing the company so that these reviews occur before, not after, the modification is implemented.

Types of change that need to be managed

Not all changes are of the same nature or require the same analysis. A practical classification distinguishes four families, which are often combined:

• Technical changes. New machines, modification of existing equipment, substitution of substances or mixtures, new materials, renovations of electrical, ventilation or fire protection installations, and automation of tasks.
• Organizational changes. Shifts and schedules, production rhythms, reassignment of functions, outsourcing or insourcing of activities, new contracts, teleworking, mergers and restructurings.
• Changes in personnel. New hires, replacements, promotions to positions with new responsibilities, temporary workers, people with special needs or requiring job adaptations, and departures of personnel with critical knowledge of a process.
• Regulatory or requirement changes. New legislation, modification of limit values, customer or certification requirements that necessitate reviewing procedures and controls.

In addition to its nature, its duration is also important. A permanent change is integrated into the system assessment and documentation. A temporary change, such as a temporary line rerouting or a replacement machine during a breakdown, requires a rapid analysis, a defined timeframe, and a return-to-original status date. An emergency change, implemented without planning time to prevent further damage, must be recorded and assessed as soon as the situation allows, because improvised changes are a known source of accidents.

How is change management applied?

The procedure must be provided to the organization: a small business can handle it with a checklist and a meeting; a chemical plant will need a formal process with approvals. In all cases, the steps are the same.

1. Detecting change: defining what constitutes change, who should communicate it and through what channel, so that purchasing, maintenance, production, human resources and recruitment know that a modification activates the procedure.
2. Describe the change and its scope: what is being modified, where, from when, for how long and which people it affects, including contractors and visitors.
3. Identify hazards and assess new or modified risks, also checking if the change cancels or weakens existing measures, such as safeguards, extractions, signage or procedures.
4. Define preventive measures following the principles of preventive action, assign responsibilities and deadlines, and incorporate them into the preventive planning.
5. Inform and train the people affected before implementation, and consult with workers’ representatives when the change affects the organization of work or the introduction of new technologies.
6. Authorize implementation only when prior measures have been executed; verify after a defined period that the residual risk is as expected and update the assessment, procedures and training.

Prior consultation is not an optional procedure. Law 31/1995 recognizes the right of workers and their representatives to be consulted on work planning and organization, and on the introduction of new technologies, particularly regarding the consequences for safety and health. Integrating this consultation into the change process prevents having to redo decisions already made.

Who participates and what information do they need?

Change management fails when it is left solely in the hands of the prevention service. Change originates in other departments and must be detected there.

• Management and leadership. They decide on the change, approve its implementation, and are responsible for ensuring that the prior measures are followed.
• Purchasing, engineering, and maintenance. They specify equipment, substances, and facilities; they must incorporate preventive requirements into the specifications and communicate any modifications.
• Human Resources. They communicate new hires, job changes, shifts, and temporary contracts that require training, information, or adaptation.
• Prevention service. Advises, assesses the risks of change, proposes measures and verifies their effectiveness.
• Workers and their representatives. They provide knowledge of the actual work and should be consulted and informed.

The minimum information required to evaluate a change includes the technical description (manuals, declarations of conformity, safety data sheets), the diagram or sequence of the affected process, the current risk assessment for the workstation, existing measures that may be altered, and the history of related incidents. Without this information, the analysis becomes merely a meaningless signature of conformity.

Evidence, review, and common mistakes

A change management process leaves verifiable evidence: the change record with its scope and timeframe, the updated risk assessment, the measures incorporated into the preventative plan, the documentation of information, training and consultation, the implementation authorization, and subsequent verification. This evidence is what audits examine and what allows for reconstructing why a decision was made.

The most common mistakes are these:

1. Consider only the purchase of a machine as a change and forget about organizational, staffing or contract changes, which are the most frequent.
2. Evaluate after implementation, when it is no longer possible to modify the design without cost.
3. Do not set an end date for temporary changes, which end up becoming permanent without evaluation.
4. Not checking if the change cancels existing measures: a new layout can make an extraction or evacuation route pointless.
5. Omitting training and information for affected individuals and contractors.
6. Failure to verify after commissioning or update documentation, so the assessment describes a plant that no longer exists.

The procedure should be reviewed when an incident reveals an unmanaged change, when the organization grows or transforms, and in any case, with the frequency that the company sets in its prevention plan.

Regulatory framework in Spain and international references

• Law 31/1995, article 16. It requires repeating the initial assessment when choosing equipment, substances or chemical preparations, introducing new technologies and modifying the conditioning of workplaces, and updating it when working conditions change.
• Law 31/1995, article 33. Right of workers to consult on the planning and organization of work and the introduction of new technologies, in relation to their consequences for safety and health.
• Royal Decree 39/1997, articles 4 and 6. General content of the assessment, including its extension to the changes indicated by the Law, and review of the assessment in the event of damage or inadequate controls and with the agreed periodicity.
• Directive 89/391/EEC, Article 6. Obligation to take into account the evolution of technology and to consult workers in the planning and introduction of new technologies.

The ILO’s ILO-OSH 2001 guidelines include change management as an element of the management system and recommend assessing risks before introducing internal or external changes. ISO 45001 contains an equivalent requirement for organizations that adopt it voluntarily; neither standard is directly applicable in Spain.