In most cases, a proposed project will result in changes. This may be an obvious change to a current process or operation that affects your entire business model. Or, it may be a subtle change to a process which may alter safety, health, and environmental aspects at the facility. In any case, proper management of change may be the difference between a successful project and one that is riddled with failures.
What is management of change? The process may look different for each facility, but essentially it is a systematic approach to ensure that all applicable safety, health and environmental aspects for the process are considered prior, during, and after the process change.
For industries subject to environmental regulations, proposed changes to operations may impact existing permits (i.e. air permits, stormwater conveyance, wastewater effluent, hazardous waste generation, etc.)
In some cases, the impacts resulting from a change may not be so obvious. For example, consider the replacement of a tube bundle within a heat exchanger. The intended purpose is to increase surface area within the exchanger to provide more heat to the process. As a result, this change reduces the processing time for the operation due to improved heat availability. Heat exchangers are not typically reflected as a source in most air operating permits; therefore, the facility may not consider the implications to their air operating permit prior to implementing the change. However, reduced processing time due to increased exchanger performance provides for an increase in the overall maximum production rates for the process. Increasing the maximum production rate for the process will change the facility’s potential-to-emit (PTE), which is the foundation of the facility’s air operating permit. In this example, from the perspective of the air operating permit, a change implemented to an external or auxiliary system had a direct impact to an environmental aspect at the facility.
It is important to initially evaluate all potential outcomes for a process change prior to implementation, as the effect could result in permit violations, enforcement cases, increased safety risks, etc. The management of change evaluation should be conducted early in the project lifecycle to address all potential changes and mitigate risk for environmental, health, and safety requirements.