Last reviewed 22 July 2020
What happens to a company’s health and safety management system when there is a major organisational change? Mike Sopp investigates some of the matters that need to be taken into account.
For many organisations, some form of organisational change is inevitable in response to dynamic internal and external influences. Organisational change (or business re-engineering, as it is also known) is not only an opportunity for a business to improve practices and systems but can be an opportunity to improve health and safety.
However, the Health and Safety Executive (HSE) says that its experience is that, “in many instances organisational changes are not analysed and controlled as thoroughly as plant changes”.
For the health and safety practitioner, the challenge is to develop and apply a process of identifying, reviewing and acting on safety issues as part of the change process.
Change and impacts
The global economy is a dynamic environment that can be subject to many influences that require those operating in the environment to change their business operating model.
Innovation is being introduced, through new technologies, deregulation and alternative employment practices, in an attempt to reduce costs and/or to make organisations more productive. Typically, such innovation can result in:
restructuring, with changes to key personnel, roles, responsibilities, teams or departments and increased matrix management
downsizing, accompanied by increased outsourcing, multi-skilling, flexible working, reduced/flattened hierarchy, self-management and increased automation
changes to administrative arrangements and working practices, such as working hours, staff relocation and new equipment.
From a risk management perspective, research by the HSE has found that many organisations undertake a change process “without carefully considering the implications for risk to their operation, even though the organisations appear fully aware of safety management issues”.
Typically, these risks may materialise through:
a loss of talent, skills and knowledge from the organisation with remaining employees having limited competency in new areas of responsibility
an increased use of contract staff, who may be unfamiliar with, or inexperienced in, the hazards and associated risk control systems
employees with reduced morale and increased workloads, leading to “overloading” of employees
the removal of “hazard barriers” through self-management, limited supervision and safe systems of work that are no longer fit for purpose
unclear objectives, reporting arrangements and accountability relationships
the health and safety management system or culture being misaligned with new operating models.
The key issue is to ensure that the direct and indirect effects of a proposed change on the control of hazards are identified and assessed through the application of an appropriate change process.
This is recognised in formal management system standards such as BS ISO 45001, which states that “the organization shall establish a process(es) for the implementation and control of planned temporary and permanent changes that impact OH&S performance”.
It is important to determine what would constitute a “significant change” and require a formal management process, and what could be managed within the existing management system.
HSE Research Report 123 Business Re-engineering and Health and Safety Management — Best Practice Model contains a number of suggested substantive changes including “significant reduction in staffing levels without a proportionate reduction in workload” and “changes in reporting lines, allocation of accountabilities and responsibilities”.
Health and safety should be managed in the same planned and informed manner as all elements of reorganisation. This is based on:
getting organised, by having senior managers’ commitment and accountability in place, along with a clear policy, change-management procedure and communication arrangements
assessing the risk, so as to identify all changes and persons affected, taking into account the human factors, competence and workloads
implementing and monitoring the change process, ensuring that sufficient resources are committed and that regular monitoring takes place during and after the change implementation.
From the health and safety perspective, any change process should not only be seen as a requirement to ensure continued compliance, but also as an opportunity to improve performance.
It may be useful, as part of any formal process, to detail the objectives of the change process, which may include:
using the reorganisation as an opportunity to identify and implement improvements to the management of health and safety
assessing and reviewing the reorganisation to ensure that there are no unforeseen or adverse impacts on the health and safety risk profile
providing assurance to stakeholders that adequate health and safety standards have been maintained both during and after the reorganisation
ensuring full compliance with all applicable health and safety regulations, with an expectation that performance standard would subsequently improve.
Senior management commitment is essential and an influential senior manager should be made the sponsor or champion for the health and safety-related change process. He or she should ensure the safety aspects of the change receive an appropriate level of resource and attention.
Effective, formal change process procedures, consultation and communication arrangements are important elements of success. These will enable the early identification of potential impacts as well as potential improvements.
Assessment and implementation
Risk assessing in the change process should identify risks and opportunities resulting from the change and from the process of change itself, which is likely to result in a change to the risk profile of the organisation.
Depending on the significance of the change, its complexity and current risks, it may be possible to review a current risk assessment or assessments. Alternatively, where there have been for significant changes, it may be necessary to complete a new assessment, possibly at a strategic level.
According to the HSE, “the key aim of risk assessment is to ensure that, following the change, the organisation will have the resources, competence and motivation to ensure safety without making unrealistic expectations of people”.
The assessment can be based on the mapping of tasks and individuals from the old organisational model to the new organisation and the use of scenario assessments, which are appraisals of the adequacy of proposed new arrangements in a range of foreseeable upsets, incidents and emergencies.
The assessment process should be completed by well-trained individuals and preferably they should be independent of the facility being assessed. However, the HSE states that assessments should be “fully participative, ensuring that the knowledge and views of people involved are gathered and given dispassionate consideration”.
The assessment needs to identify potential workloads, including any “peaks and troughs”, infrequent tasks (eg maintenance) and cover for sickness and leave, work priorities and the skills, knowledge and experience required to undertake work activities.
Research indicates that health and safety changes are often seen to be a related yet separate set of issues within the organisational change process. However, to ensure the effective implementation of any additional actions, these need to form an integral part of the overall change process planning. Implementation should:
be phased to prevent loss of control through over-complexity and avoid peaks in workload
ensure that there is adequate cover to allow any extra work that is needed, such as training, writing new procedures or systems of work
arrange for ample support and/or supervision by competent people for all people with new health and safety-related roles and responsibilities.
However, it must be borne in mind that the timescales for change will be influenced by many factors.
There will always be a degree of uncertainty about the impact of organisational change and the effects of change can be quite subtle or delayed. Periodic, planned reviews should assess whether the actions deemed necessary have been effectively implemented or whether additional action is required.
Change is an inevitable factor for all organisations with many internal and external influences.
This can include new products, services and processes, or changes to existing products, services and processes, including workplace (eg locations, organisation, conditions or equipment), changes to legal requirements and other requirements, changes in knowledge or information about hazards and OH&S risks and developments in knowledge and technology.
The key to successfully managing any change is to proactively manage that change and take the workforce with the change process.
Determining the impact of change on the organisational risk profile will help inform what, if any changes to the health and safety management system are required.
The necessary changes can then be identified, be they in respect of new risk control measures, for example, additional training or, changes to policy and procedures.
Further information from the HSE
CRR 123 Business Re-engineering and Health and Safety Management — Best Practice Model
CRR 348 Assessing the Safety of Staffing Arrangements for Process Operations in the Chemical and Allied Industries
Human Factors Briefing Note 11 Organisational Change
Chemical Information Sheet CHIS7 Organisational Change and Major Accident Hazards