As the PV manufacturing industry continues to mature, addressing the need to continuously and safely update both R&D and manufacturing equipment will require robust “management of change” policy and processes. Dale Goss and Robert Barnes discuss the framework for the development and implementation of such a program.by Dale Goss, EORM, and Robert Barnes, Robert B. Barnes Associates Inc.
In an initial article on photovoltaic (PV) environmental, health, and safety (EHS) (” Sustainable, environmentally responsible controls and practices for the PV industry“, May 14, 2009), we acknowledged the similarities and best management practices between both the PV and semiconductor industries, which provide an opportunity to leverage the strong EHS foundations developed over many years by the semiconductor industry. As the PV manufacturing industry continues to mature, addressing the need to continuously and safely update both R&D and manufacturing equipment will require establishing robust “management of change” policy and processes. This article discusses this need and provides the framework for the development and implementation of a successful management of change program.
What is “management of change” policy
PV companies are faced with a myriad of complex business and EHS challenges that are compounded by the industry’s rapid growth. Over the last five years this market area has catalyzed the birth of new companies, developed specialized manufacturing facilities, and attracted a wide range of employees to support this dynamic new industry in widely dispersed geographic locations.
As the PV industry continues to mature, the need to continuously update both laboratory and manufacturing equipment in order to remain competitive will be essential for the survival of many of these companies. Fortunately, the semiconductor industry — and in particular, thin-film and display segments — have developed a process to better manage and handle such evolution.
Today, many businesses committed to conducting their operations in a manner that sustains the environment, protects the health and safety of their workers, and reduces business interruptions, have included a “management of change” (MoC) policy to equipment and/or operations as a key part of their corporate programs. This outlines the requirements for evaluating proposed changes to manufacturing processes/equipment, research and development processes/practices, and associated infrastructure for their potential EHS impacts.
Organizational responsibilities for managing change
The ultimate goal of the EHS aspects of a MoC program is to identify and reduce potential impacts — and thereby protect the business, its workers, and the environment from any adverse affects.
The scope of business activities typically requiring use of MoC business processes/procedures to minimize the potential for unintended consequences related to EHS compliance and risks include, but are not limited to, the following:
— product development;
— facilities planning, design, construction and maintenance support;
— product manufacturing; and
— general administration, sales, and information management.
A successful MoC program requires a collaborative team effort to include employees from EHS, facilities, equipment/tool owners, and building owners or managers involved directly in the change process. The responsibility of each team member is to evaluate the proposed changes and, through a process of facilitation and documentation, formally agree upon the specific conditions under which the proposed changes are acceptable. These individuals own the responsibility to review the changes prior to restart, so as to verify that the changes have been made according to plan.
Changes typically requiring review for EHS aspects or issues include, but are not limited to:
— New products release;
— Increase in energy and/or water usage;
— Introduction (or increase) of new chemical and physical agents;
— Moving equipment or modifications of workflow within existing facilities that require decommissioning or decontamination;
— Facility and/or property transfers;
— Preventive and corrective maintenance procedures and controls; and
— Organization and staffing;
— Off-site consequence impact to and/or from a neighboring business.
Sample MoC process
The MoC initiator completes a MoC checklist answering specific questions regarding the proposed changes to the process and/or equipment. The checklist is worded such that specific questions call for additional review by other employees responsible for ownership of the tool or process (such as tool owner, facilities, building owner or manager, and EHS personnel) for their approval and signatures.
Typically, after the tool owner or business manager reviews and approves the MoC checklist, it is sent to facilities personnel to review for impacts to facility support systems. If the changes are deemed unacceptable, risks associated with the proposed changes are identified and addressed; these may include facilities, safety, and/or environmental concerns. The initiator, with appropriate support and assistance, will determine whether an alternative modification can be utilized. EHS personnel then provide the final review of the completed MoC checklist.
After agreement on the changes by all parties involved that the change is complete, a pre-start-up inspection (” EHS considerations in PV manufacturing equipment installations“, June 17, 2009) should be completed with the initiator, tool owner, facilities, and EHS to ensure that identified hazard controls are fully operational prior to start-up. The tool owner or business manager will also ensure that personnel affected by the change are provided with information related to potential safety issues and training requirements for the modification.
At times, an additional step to the MoC process may include decommissioning of obsolete systems, often described as the process of safely bringing down and disassociating a system, sub-system, or components. This includes the entire process of decontamination, defacilitation, and demolition. For more information about managing the decommissioning process, request a copy of ” Select the Best Decommissioning and Relocation Team” from the authors.
In closing, PV companies who strive for continuous improvement in its environmental, health and safety management systems, and in the environmental and safety performance, will find the MoC process a beneficial component to their organizations. Due to the complexity of today’s manufacturing environments and the myriad regulatory compliance requirements, the MoC process will certainly help streamline efficiency, reduce business interruptions, and help keep your company competitive in this ever changing business landscape.
Dale Goss, (MBA, MPH) is senior EHS consultant at Environmental and Occupational Risk Management (EORM), e-mail firstname.lastname@example.org.
Robert Barnes is president of Robert B. Barnes Associates Inc.; e-mail RBarnesAZ@aol.com.